Ems example documents

Environmental Management Office
Pueblo Chemical Depot
Environmental
Management System
(EMS)
What is the purpose of the
PCD
EMS in 2 words?
* Continuous Improvement *
Environmental Management
Office
Phone: 549-4201
ADVANTAGES OF EMS
EMS makes systematic management of environ-
mental activities a tool for PCD accomplishment.
EMS can enhance our performance by:
 Aligning programs and environmental
goals
 Facilitating communication of environmen-
tal issues
 Prioritizing limited resources around miti-
gating risks to our goals
 Providing clear objectives based on PCD
defined factors such as program impact
And community concern – not just
compliance
 Prioritizing program resources around risks
that impact the goals of PCD
 Facilitating communication with stakehold-
ers outside the fence line and building
stronger relationships with the community
and regulators
 Eliminating unnecessary compliance bur-
dens, increasing operational flexibility and
reducing total ownership costs through
participation in various EMS incentives pro-
grams.
PCD EMS Benefits
 Improved understanding of key envi-
ronmental issues and their impact on
our mission and community.
 Increased efficiency and use of ener-
gy and materials, thus reducing
waste.
 Improved ability to meet legal com-
pliance requirements.
 Reduced number and scope of nega-
tive impacts to the environment from
military operations.
 Reduce wastes
 Improved image and relationship
with the local community.
(continued)
IV. Checking
 Monitoring and measurement
 Evaluation of compliance
 Nonconformance, corrective action and
preventive action
 Control of records
 Internal audit
V. Managerial review
 Management review (EQCC)

What is an EMS? (continued)
 Compliance: Compliance with all applicable
legal and regulatory requirements
concerning protection of the environment is
a priority for PCD. Any instance of
noncompliance will be promptly corrected
and appropriately reported.
 Pollution Prevention: PCD will adhere to the
following preferences, in descending order,
for managing pollution and waste generated
at this site: source reduction, recycling,
treatment, and then disposal. PCD will
monitor the use of raw materials and utility
resources for potential improvements in
efficiency or environmentally beneficial
alternatives. PCD will recycle as much
possible and use recycled materials when
economically beneficial.
 Continuous Improvement: PCD will
consistently improve performance in
ensuring environmental responsibility.
Measurable environmental goals, updated
objectives, and targets will be reviewed and
updated annually. PCD will implement, a
continuous program of critical
improvements in practices that benefit the
environment.
PCD EMS
EMS is part of the overall Pueblo Chemical
Depot (PCD) management system that
specifically addresses the potential
environmental risks from Depot activities.
Pueblo Chemical Depot (PCD) is committed to
be a good steward to the land surrounding
communities by maintaining a healthy
environment of the land, water, air and
natural resources it is entrusted with. The
Environmental Quality Control Committee
(EQCC) is the centerpiece of our EMS and
serves as the corporate governing body or
“top level management” team. The Depot
Commander is the Chair of the EQCC with all
senior Depot leadership as EQCC members.
The EQCC includes PCAPP as a stakeholder in
the EMS of PCD.
ISO 14001 EMS International Standard
Plan > Do > Check > Act
I. Environmental policy
 Environmental policy
II. Planning
 Environmental aspects
 Legal and other requirements
 Objectives, targets and program s
III. Implementation and operation
 Resources, roles, responsibility and authority
 Competence, training and awareness
 Communication
 Documentation
 Control of documents
 Operational control
 Emergency preparedness and response
PCD’s EMS four pillars are:
 Stewardship: PCD will be sensitive to the
effects of our activities on human health
and the environment because we believe
in stewardship of the resources to which
we have been entrusted. PCD will maintain
environmental conditions while pursuing
cleanup of legacy contamination to
improve value of future generations.

EMS
Environmental
Management
System
ISO 14001: 2004
Four Pillars of EMS
1. Stewardship
2. Compliance
3. Pollution Prevention
4. Continuous Improvement

Environmental
Policy Locations
1. Official Bulletin Board
2. Depot Intranet
Know how your job affects
the Environment!
Environmental accidents are
caused by a cluttered work
area:
Keep your work area clear!
Any questions call:
Environmental Management
Office 719-549-4547

UNCONTROLED IF PRINTED PCD EMS Manual
1-1
December 2011
EEMMSS MMaannuuaall
August 2009

1-2
Table of Contents
1. Introduction to the Pueblo Chemical Depot (PCD) EMS Manual........................................................................... 1-3
1.1 Purpose of the EMS Manual...................................................................................................................................... 1-3
1.2 EMS Manual Maintenance........................................................................................................................................ 1-3
1.3 EMS Implementation at PCD .................................................................................................................................... 1-3
1.4 EMS Glossary............................................................................................................................................................ 1-4
1.5 EMS Acronyms .......................................................................................................................................................... 1-9
2. PCD Scope and Characteristics .................................................................................................................................. 2-1
2.1 PCD Background & Mission..................................................................................................................................... 2-1
2.2 PCD Facility Description.......................................................................................................................................... 2-2
2.3 PCD Significant Environmental Aspects ................................................................................................................. 2-4
3. PCD Environmental Policy ......................................................................................................................................... 3-1
4. EMS Procedures........................................................................................................................................................... 4-4
4.1 Identifying Significant Environmental Aspects ........................................................................................................ 4-6
4.2 PCD EMS Audit Program ....................................................................................................................................... 4-15
4.3 PCD EMS Procedure for Internal and External Communications.......................................................................... 4-31
4.4 PCD EMS Procedure for Document Control and Documentation.......................................................................... 4-34
4.5 PCD EMS Procedure for Environmental Management Programs and Operational Controls ............................... 4-36
4.6 PCD EMS Procedure for Addressing Emergency Preparedness and Response ..................................................... 4-41
4.7 PCD EMS Procedure for Legal and Other Requirements....................................................................................... 4-43
4.8 PCD EMS Procedure for Monitoring and Measurement ........................................................................................ 4-45
4.9 PCD EMS Procedure for EMS Management Review.............................................................................................. 4-47
4.10 PCD EMS Procedure for Nonconformity, Corrective and Preventive action......................................................... 4-49
4.11 PCD E MS Procedure for Setting Objectives and Targets...................................................................................... 4-51
4.12 PCD EMS Procedure for the Control of Records ................................................................................................... 4-54
4.13 PCD EMS Procedure for Competency Training..................................................................................................... 4-56
5. EMS Records................................................................................................................................................................ 5-1

1-3
1. Introduction to the Pueblo Chemical Depot (PCD) EMS Manual
The original requirement for an Environmental Management System (EMS) was issued by
Executive Order (EO) 13148, “Greening the Government through Leadership in Environmental
Management.” Army Memorandum, ACSIM, DAIM-ZA, 10 July 2003, SAB requires EMS
implementation via International Organization for Standardization (ISO) 14001. The Pueblo
Chemical Depot (PCD) Policy Statement Number 20, 17 September, 2011, defines PCD’s
environmental goals and mission. This manual defines PCD’s implementation, roles,
responsibilities, and procedures for defining and maintaining the PCD EMS.
1.1 Purpose of the EMS Manual
This Environmental Management System Manual serves as a repository for documentation related to the
Pueblo Chemical Depot (PCD) Environmental Management System (EMS) and includes:
a. EMS Procedures that describe how to carry out key tasks within the EMS such as training,
tracking legal and other requirements, or managing records.
b. Programs & Controls that operate under the EMS, such as programs for achieving EMS
objectives and targets or for carrying out EMS audits.
c. EMS Records that confirm the completion of specific EMS activities such as the
identification of environmental aspects, the conduct of EMS training, or that management
reviews were completed.
d. Definitions and References that provide additional information useful to individuals
reviewing or learning about the EMS.
1.2 EMS Manual Maintenance
a. This EMS Manual is maintained by: PCD EMS Manager or someone designated by him.
b. The formal version of this EMS Manual is located in the Environmental Management Office,
PCD.
c. This EMS Manual was last updated on: June 2010
d. In addition to the tables created to identify significant aspects and objectives and targets, the
EMS Manual contains the EMS Audit Program, the EMS Procedures, EMS records, and
other descriptive information useful to anyone being introduced to the EMS or to those
responsible for the EMS.
1.3 EMS Implementation at PCD
The Pueblo Chemical Depot (PCD) has implemented an Environmental Management System (EMS) to
ensure it fulfills the commitments to its Environmental Policy. The scope of the PCD EMS includes the
following facilities and organizations within the Pueblo Chemical Depot (PCD. The EMS is modeled on
the specifications found in the international standard for environmental management in organizations, ISO-
14001:2004. Specific benefits provided to PCD from implementing a formal management discipline
include:

1-4
a. The systematic approach to managing PCD’s potential impacts on the environment.
b. Enabling PCD environmental concerns to be managed to accord with mission goals.
c. Providing documentation of existing processes so that results can be repeated. Institutional
knowledge is captured so it is not subject to personnel flux.
d. Providing a structured approach to identify potential impacts that could otherwise result in
costs, embarrassments, and threats to mission.
e. Having the potential to provide employees with a sense of empowerment that can translate to
enhanced performance on the job.
f. Providing the site with a means to track and measure environmental and operational
performance by instituting metrics.
g. Providing greater discipline and assurance in tracking and analyzing environmental
requirements thus ensuring a higher level of compliance.
h. Allowing PCD to use a risk management approach ensuring the site focuses and allocates its
resources to those that have the greatest probability and worst potential consequences.
i. Providing for greater sharing of knowledge and responsibilities across all levels and
functions.
j. Supporting reporting under Government Performance Results Act (GPRA).
1.4 EMS Glossary
Adequacy: Refers to the sufficiency of the resources for the EMS.
Auditor Training: Training provided to those individuals that will fulfill the role of internal EMS
auditors at PCD. This includes basic EMS training, familiarization with the organization's own EMS, as
well as training on how to prepare, conduct and conclude the internal audit, including writing the audit
report and overseeing the completion of corrective actions on the audit findings.
Competence Training: Training provided to personnel that are associated with significant
environmental aspects. Such training is indicated when the individual is not considered competent on
the basis of previous training, education, or experience to address the responsibilities he/she has been
charged with relative to the significant environmental aspect in question.
Compliance Audit: A periodic audit of compliance with regulatory and other requirements that are
imposed on the organization. Findings are expressed as non-compliances. The search for root causes in
a typical compliance audit may not be as intense as it should be during an EMS audit.
Continual Improvement: Process of enhancing the EMS to achieve improvements in overall
environmental performance in line with the organization’s environmental policy. (Note: Continual
implies that there will be periods where improvement will be flat.)
Correction: The totality of immediate and long-term steps taken to mitigate the consequences of a
nonconformity (e.g., cleanup of spilled hazardous material; remediation of groundwater; natural habitat
restoration). The correction does not by itself remove the underlying cause of the nonconformity.
Corrective Action: Action to address the underlying cause of an actual event that has been identified as
a non-conformity through an audit.
EMO Program Manager: An individual in the Environmental Management Office (EMO) appointed
to manage specific environmental programs and/or plans for media protection and resource conservation
such as air, groundwater, surface water, soil, cultural resources, and pollution prevention.
Effectiveness: Refers to the accomplishment of the objectives and targets set for the EMS.

1-5
Environmental Impact: Any change to the environment, whether adverse or beneficial, wholly or
partially resulting from the facility’s aspects. (Note: A potential environmental impact is equivalent to
the concept of risk, in safety, which assigns a probability and consequence to the possible negative event
that may result from a hazard.)
Environmental Aspect: An element of an activity that can interact with the environment. (Note: The
environmental aspect of an activity is that part of the activity that creates the possibility for an
environmental impact. As such, it is equivalent to the concept of hazard, in safety, which is also defined
as the mere possibility of a negative event.)
Environmental Management Programs: Are a management tool used to document the tasks,
responsibilities, and other operational details that are implemented to achieve the objectives and targets
that are set for the significant aspect. They include timelines, resources, and responsibilities for
achieving
those objectives and targets and are amended as necessary with changing environmental, organizational,
and legal requirements, as well as aspects and operations within the organization.
EMPs incorporate a number of other EMS components including:
 The significant environmental aspect that is being addressed;
 The objective(s) and target(s) that were set for the significant aspect;
 The program indicators to be used to measure progress in achieving the objectives and
targets;
 The factors that gave rise to the significance of the aspect;
 The programmatic tasks needed to achieve the objectives and targets;
 The roles and responsibilities of individuals responsible for the tasks;
 Declarations of employee competency;
 Specification of records to be produced by executing the management plan;
 Reference to other documents used with the management plan; and
 Operational controls that are implemented to ensure that the objectives and targets will be
achieved as planned.
Environmental Management System Manager: An individual appointed by top management to serve
as management representative and coordinator ensuring that the EMS is established, implemented and
maintained in accordance with the requirements of the ISO 14001:2004, and also report to top
management on the performance of the EMS for review, including recommendations for improvement.
Environmental Objective: Overall environmental goal, arising from the environmental policy that an
organization sets for itself to achieve, and which is quantified where practicable.
Environmental Performance: Measurable results of the EMS, related to an organization’s control of
its environmental aspects, based on its environmental policy and objectives and targets.
Environmental Policy: Statement by the organization of its intentions and principles in relation to its
overall environmental performance that also provides a framework for action and for setting of its
objectives and targets.
Environmental Program Indicator: A specific datum selected, such as volume of a chemical used,
which will provide measurable information regarding progress toward meeting a specific environmental
objective and target.

1-6
Environmental Target: Detailed performance requirement, quantified where practicable, applicable to
the organization or parts thereof, that arises from the environmental objectives and that needs to be set
and met in order to achieve those objectives.
Executive Overview Course: A briefing provided to the relevant officer staff and other top
management at PCD on the EMS. This briefing familiarizes these individuals with general EMS
concepts and with selected elements of the EMS that they ought to be familiar with. Most specifically, it
lays out their roles and responsibilities with respect to the EMS, including their roles in establishing the
PCD Environmental Policy and in conducting the periodic Management Reviews.
External communication: Communication to parties or organizations external to PCD’s physical site
boundaries or its functions and activities.
External interested party: Individual or group concerned with or affected by the environmental
performance of PCD.
General Environmental Awareness Training: Training that is provided to all personnel irrespective
of whether they are associated with significant environmental aspects.
Implementation Training: Training provided, if needed, to those responsible for implementing or
supporting the EMS. This course instructs attendees on the basic principles of the EMS, provides
sample procedures that can be adapted by the organization, suggests the use of certain templates that
simplify implementation, and discusses the resources and organizational support required for the EMS
development and implementation effort.
Incident or Emergency: Constitutes more than a mere nonconformity in the EMS. Any event that
invokes the ISCP. For purposes of the EMS, nonconformities that do not invoke the ISCP will be
corrected through the provisions of the PCD “Non-conformance and Corrective and Preventive Action
Procedure.” Responses to emergencies such as fires, floods, and earthquakes are managed through the
National Incident Management System (NIMS), Incident Command System (ICS). If the emergency is
severe or long lasting, the PCD Emergency Operations Center (EOC) may be activated.
Inputs, Products, and Services: Term used to encompass the everyday activities of an installation.
Includes, but is not limited to training on ranges; munitions testing; construction and renovation of real
property; manufacturing activities; commercial services such as dry cleaning, photo processing, etc.;
wash rack operations; grounds maintenance; vehicle maintenance; etc. (In this procedure the term
Inputs will be used in place of the full term Inputs, products and services and is synonymous to the term
“activities” found in the ISO-14001:2004 standard)
Installation Spill Contingency Plan (ISPC): A plan implemented immediately whenever there is a
potential or an actual event such as fire explosion or release of oil or hazardous substances/waste. The
ISCP meets the requirements of 40 CFR 264 (RCRA).
Installation Sustainability Team (IST): Team of facility personnel representing various installation
activities and tenants selected by their organizational leader to serve as representatives for the various
functional areas on the installation. The team’s responsibilities are to gather, organize, and disseminate
information; help to develop EMS procedures; advise, coordinate, facilitate, and monitor EMS
implementation; and assist the EMS Program Manager with EMS-related matters.
Interested Party: Individual or group concerned with, or affected by the environmental performance of
an organization.

1-7
Internal Communication: Communication within PCD that is intended for personnel to further the
EMS goals.
Internal EMS Audit: A periodic audit of the EMS to verify that it is properly implemented and that it
continues to conform to planned arrangements for environmental management. It is an audit of the
system and findings are expressed as non-conformities. Audit conclusions are based on the findings and
focus on the root causes that led to the non-conformities. It is appropriate to seek the root causes of
known compliance findings during an EMS audit, since these may reflect EMS deficiencies.
Legal Requirements: EMS legal and other requirements encompass all the constraints imposed on PCD
to control its environmental aspects and operations. These constraints include federal, state, and local
laws and regulations, environmental permits, registrations, executive orders, and consent decrees. In
addition, internal organizational procedural requirements pertaining to environmental aspects such as
military (e.g., Department of Defense [DoD] and Department of Army [DA]) instructions, directives,
manuals, and policy decisions also apply. These internal requirements take on the same importance as
legal requirements and are expected to receive the same degree of commitment to compliance.
Non-compliance: Failure to meet regulatory or other requirements that have been imposed on the
organization.
Non-conformity: Any deviations from established procedures, programs and other elements of the
EMS. They may include non-compliance with regulations, but not all instances of non-compliance are
necessarily non-conformities of the EMS.
Operational Controls (OCs): Mechanisms (technological or administrative) used to maintain a desired
level of environmental performance. OCs are applied to PCD Inputs to prevent the environmental
aspect they exhibit from occurring. Shop Environmental Instructions will be develop to inform
personnel of environmental responsibilities. Examples of OCs include those built into technology (e.g.,
motion sensors, sleep mode for electronics, etc.), those requiring operator intervention (e.g., selecting
duplex printing, electronic documents, etc.), and those that are incorporated in standard operating
procedures (SOPs) (e.g., procedure for storage and disposal of hazardous waste).
 Each significant environmental aspect shall be reviewed in conjunction with its inputs to
determine whether OCs (either technological or administrative) are needed for those inputs.
 In doing the review, special attention shall be given to those characteristics of Inputs that
necessitate OCs.
 Where applicable, documentation on the OCs will specify the operating criteria (including
maintenance) and the actions to be taken when they are interrupted, or when they might
otherwise fail.
 When necessary, OCs will also be applied to the identifiable significant environmental
aspects of goods and services that are received from external sources and used at PCD.
When appropriate, OCs that need to be implemented by the external source shall be duly
communicated to those sources. (Refer to EMS Communications Procedure, if applicable)
 Operations managers are responsible to ensure that OCs are implemented for those inputs
that are within their purview and that contain significant environmental aspects. OCs will be
integrated into Shop Environmental Instructions (SEIs) as those are developed and
implemented across operations at PCD.
Personnel: All persons working at PCD, including contractors that are on PCD for greater than 6
months.

1-8
Preventive Action: Action to prevent potential problems before they occur at other areas or functions
of the organization that may have similar vulnerabilities to that which caused the original non-
conformity. . Preventive action can be focused on identifying negative trends and addressing them
before they become significant.
Record: A document stating results achieved or providing evidence of inputs performed (ISO
14001:2004 definition). A record is a permanent document that typically is not revised. Records will
include:
 Information on compliance with applicable legal requirements and other requirements to
which the organization subscribes,
 Details of nonconformities and corrective and preventive actions,
 Results of environmental management system audits and management reviews, information
on environmental attributes of products (e.g. chemical composition and properties),
 Evidence of fulfillment of objectives/targets,
 Information on participation in training,
 Permits, licenses or other forms of legal authorization,
 Results of inspection and calibration activity, and
 Results of operational controls (maintenance, design, manufacture).
Relevant Communications: Verbal or written inquiries deemed appropriate for response based on
installation policy and concern for confidentiality.
Root Cause Analysis: Root cause analysis is the method used to identify immediate, underlying and
root causes of an incident. The analysis of the root causes aims to find the proper corrective and
preventive actions to apply to remove those causes and thereby prevent both a recurrence of the incident
and its potential future occurrence in other parts of the organization.
Significant Environmental Aspect: An environmental aspect that has, or can have, a significant
environmental or mission impact (i.e., one that can potentially cause a significant environmental or
operational impact).
Spill Prevention, Control and Countermeasures Plan (SPCCP): The plan are required by Section
311(j) of the Clean Water Act to establish procedures and guidance for the prevention, detection, and
response to releases, accidents, and spills involving oils or hazardous substances at Pueblo Chemical
Depot.
Suitability: Refers to whether the EMS continues to accord with the nature of the organization.
Suppliers and contractors: Organizations or individuals that provide supplies, materials, services and
other tangible goods to PCD.
Top management: For purposes of this procedure, top management will include, at a minimum, the
Depot Commander or Deputy Commander and other members of the Command Staff.
Verification: A follow-up visit by the audit team to ascertain that corrections, and corrective and
preventive actions have been appropriately completed. The decision to do this is based upon the
frequency, severity, and/or risk of continued nonconformity, as well as on whether the finding was either
a major or critical audit finding.

1-9
1.5 EMS Acronyms
AAR after-action review
ABC activity-based costing
ACSIM Assistant Chief of Staff for Installation Management
AEDB-EQ Army Environmental Database - Environmental Quality
ANSI American National Standards Institute
AR Army Regulation
ARIM Army Reserves Installation Management
ARNG Army National Guard
ARTEP Army Readiness Training Evaluation Programs
BACM best available control measures
BACT best available control technology
BADT best available demonstrated technology
BMP best management practice
CAA Clean Air Act
CAAA Clean Air Act amendments
CAIRA Chemical accident/incident response and assistance
CAR corrective action report
CDPHE Colorado Department of Health and the Environment
CBT computer-based training
CDR commander
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CFCs chlorofluorocarbon
CFR Code of Federal Regulations
CFT cross-functional team
CONUS Continental United States
COTS commercial off-the-shelf
CWA Clean Water Act
DDMS Digital Document Management System
DENIX Defense Environmental Network Information Exchange
DFE Design for the environment
DoD Department of Defense
DPW directorate of public works
DSERTS Defense Site Environmental Restoration Tracking System
DTC Document Tracking Center
EAP environmental action plan
ECOs environmental compliance officers
EMO Environmental Management Office
EMP environmental management programs
EMS environmental management system
EMSMR environmental management system management representative
EMSR Environmental Management System Representative
ENFs enforcement actions
EO Executive Order
EPA U.S. Environmental Protection Agency

1-10
EPAS Environmental Program Assessment System
EPCRA Emergency Planning and Community Right-To-Know Act
EPI environmental performance indicators
EPR Environmental Program Requirements
EQCC environmental quality control committee
ESA Endangered Species Act
FAT facilities, activities and tasks
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FRP Facility response plan
FY fiscal year
GC Garrison Commander
GIS global information system
GOCO government-owned, contractor-operated
GPS global positioning system
HAP hazardous air pollutant
HAPPS hazardous air pollution prioritization system
HAZMAT hazardous material
HAZWOPER Hazardous Waste Operations and Emergency Response
HMTA Hazardous Materials Transportation Act
HOA homeowners association
HW hazardous waste
HWDMS hazardous waste data management system
ICAPs installation compliance action plans
ICS incident control center
IESIS Installation Environmental Support Information System
IMA Installation Management Agency
IMRO installation management regional office
IPR in-process review
ISO International Organization for Standardization
ISR Installation Status Report
IT information technology
METL mission-essential task list
MSDSs material safety data sheets
NAAQS national ambient air quality standards
NCA Noise Control Act
NEPA National Environmental Policy Act
NFA no further action
NLT no later than
NOV notices of violation
NOx nitrogen oxides
NPDES national pollutant discharge elimination system
OB/OD open burn/open detonation
OCONUS Outside Continental United States
ODCs ozone depleting chemicals
OFEE Office of the Federal Environmental Executive
P2 Pollution Prevention

1-11
PAO public affairs office
PAIO Program Analysis and Integration office
PCD Pueblo Chemical Depot
PL Public Law
PM2.5 particulate matter with diameter less than or equal to 2.5 microns
POC point of contact
POL petroleum, oil, or lubricant
POTW publicly owned treatment works
RCRA Resource Conservation and Recovery Act
RDT&E Research, development, testing, and evaluation
REOs regional environmental offices
RRC Regional Readiness Commands
SCP Spill contingency plan
SDWA Safe Drinking Water Act
SOP standard operating procedure
SOx sulfur oxides
SPCC Spill Prevention, Control, and Countermeasures
SPCCP Spill Prevention, Control, and Countermeasures Plan
SRS Strategic Readiness System
SS significance score
SVOC, Semi-Volatile Organic Compound
TDA Table of Distribution and Allowances
TEAM The Environmental Assessment Manual
TOE Table of Organization and Equipment
TSCA Toxic Substances Control Act
USAEC U.S. Army Environmental Center
USAES U.S. Army Engineer School
USC United States Code
UXO Unexploded Ordinance
VOC volatile organic compounds
WREO Western Regional Environmental Office – US Army

2-1
2. PCD Scope and Characteristics
2.1 PCD Background & Mission
The Pueblo Chemical Depot is located in Pueblo County, Colorado, about 100 miles southeast of
Denver and 14 miles east of Pueblo; the Arkansas River is approximately one mile south of the activity.
The facility encompasses 22,654 acres and is situated on flat to gently sloped prairie. The surrounding
lands are mostly undeveloped ranchlands used for grazing, with some light commercial and residential
zoned areas to the south.
The depot houses a chemical stockpile which comprises about 8 percent of the nation’s original
chemical materiel stockpile. This stockpile is scheduled for future destruction under the Department of
Defense Assembled Chemical Weapons Alternatives program. The depot’s current mission is the safe
and secure storage and monitoring of the chemical stockpile, preparation for destruction of the chemical
stockpile and preparation for depot closure.
Construction of the depot began in February 1942. The installation was originally named Pueblo
Ordnance Depot, and the first carload of ammunition was received in August 1942. Although originally
planned for the storage and supply of ammunition, facilities were expanded almost immediately to
receive, store, and issue general supplies to support World War II.
In 1946, Pueblo Ordnance Depot was assigned the mission of maintaining and overhauling artillery, fire
control, and optical equipment. Two years later, ammunition renovation and demilitarization were added
to that mission.
During the Korean War, shipments of general supplies and ammunition increased, and the depot reached
its highest civilian strength of nearly 8,000 employees. Missile maintenance was added to the depot’s
mission in the 1950s and in 1962, the depot was renamed Pueblo Army Depot.
The missile maintenance mission at Pueblo, with the exception of maintenance of the Pershing missile,
was transferred to Letterkenny Army Depot in 1974. In 1976, Pueblo was given depot activity status and
assigned to the Tooele Army Depot Complex.
In December 1987, the United States and the former Soviet Union entered into the Intermediate-Range
Nuclear Forces (INF) Treaty. Pueblo was assigned to disassembly and elimination activities. Pueblo
completed its INF and Pershing mission in May 1991.
Pueblo Depot Activity was in the forefront of support to Operation Desert Shield and Desert Storm,
shipping a large part of contingency stocks in addition to ammunition and supplies to Southwest Asia.
The Base Realignment and Closure Commission designated the depot for realignment in 1988. The
installation was renamed U.S. Army Pueblo Chemical Depot in 1996.

2-2
2.2 PCD Facility Description
Approximate Total number of employees: 330 Army civilian and military employees
Approximate Total number of buildings or
structures:
2,200
Approximate Property acreage: 22,654 acres
Activities that occur outside site boundaries: None
Size of EMS team: Approximately 10, including all the Environmental
Management Office personnel and individuals
representing various functions and tenant groups at
the Depot
EMS Implementation Start Date November 27, 2006
Composition of EMS team: Led by the EMS Manager with representatives from
other functions
The scope of the PCD EMS includes the following facilities and organizations within the PCD: Pueblo Chemical
Depot (PCD), Pueblo Chemical Agent-Destruction Pilot Plant (PCAPP).

2-3
Establishment of ISO 14001 EMS at Pueblo Chemical Depot

2-4
2.3 PCD Significant Environmental Aspects (See section 4.1 of this manual on the development of
the following list and its abbreviations.)

3-1
3. PCD Environmental Policy
The PCD Environmental Policy is a declaration of top management’s commitment to the environment and serves
as the foundation for the EMS. Everyone in the organization is expected to be familiar with and understand the
policy. The policy is considered when setting EMS objectives and targets, and it is understood that the
implementation of the EMS serves to make the commitments in the policy operational. The environmental policy
statement is, therefore, a vehicle for communicating the organization’s aspirations for environmental protection as
well as a functional tool for establishing the operational boundaries of the EMS. The environmental policy aligns
with the organization’s core mission and must include commitments to continual improvement, pollution
prevention, and regulatory compliance. The environmental policy statement should reflect a management
consensus on its contents and aims, and should be formalized through the signature of top management. Red
River’s environmental policy is:
Pueblo Chemical Depot's environmental policy is an integral part of our mission, and is the core of the Depot's
Environmental Management System. This policy states in broad terms the environmental commitments of Pueblo
Chemical Depot now and into the future. Pueblo Chemical Depot strives to be one of the national leaders in
environmental, energy and natural resource stewardship. Red River's primary focus areas are prevention,
compliance, restoration and conservation. The EMS program manager, Environmental Division is responsible for
Pueblo Chemical Depot's Environmental Management System. However, environmental stewardship is the
responsibility of every member of the work force, as well as its strategic partners and residents. Depot personnel
consider many environmental aspects when assessing current and upcoming projects. Personnel consider
environmental impacts of operations and activities through setting objectives and targets relevant to
environmental aspects, planning, monitoring and revisions to achieve continuous improvement of our
Environmental Management System. Pueblo Chemical Depot implements and will continue to implement new
and innovative ways to prevent pollution, minimize waste, manage natural resources and to conserve energy.
Pueblo Chemical Depot's personnel ensure that all activities comply with relevant environmental legislation,
regulations and policies. We will continue to maintain a positive relationship with the local community,
regulators and other governmental agencies.
PCD’s Environmental Policy is supplemented by specific requirements and provisions in the following additional
documents:
 AR 200-1 – Army Regulation 200-1 Environmental Protection and Enhancement
• Army Regulation 200-2, Environmental Affects of Army Actions
• Army Regulation 200-3, National Resources – Land, Forest, and Wildlife Management
• Army Regulation 200-4, Cultural Resources Management
• Air Pollution Prevention and Control Act (Clean Air Act [CAA] of 1977, as amended 42 United
States Code [USC] § 7401 et seq.)
• National Ambient Air Quality Standards, Title 40 Code of Federal Regulations (CFR) Part 50
(CAA § 109).
• Colorado Department of Health and the Environment Regulations
• Designation, Reportable Quantities, and Notification, 40 CFR 302 (CERCLA § 103)
• Emergency Planning and Community Right to Know Act (EPCRA) of 1986 (42 USC § 11001) -
Title III of the Superfund Amendments and Reauthorization Act, (Public law [PL] 99-499,
October 17, 1986, as amended by PL 102-389, October 6, 1992)
• Emergency Planning and Notification, 40 CFR 355 (EPCRA § 312)

3-2
• Executive Order 13148 - Greening the Government through Leadership in Environmental
Management
• Executive Order 13423 – Strengthening Federal Environmental, Energy, and Transportation
Management
• Executive Order 13514 – Federal Leadership in Environmental, Energy, and Economic
Performance
• Hazardous Chemical Reporting: Community Right to Know, 40 CFR 370 (EPCRA § 312)
• Federal Water Pollution Control Act (Clean Water Act [CWA] of 1972, as amended [33 USC §
1251 et seq.])
• Storm water discharges associated with industrial activity, (40 CFR 122.26 (b)(14)(i)-(xi))
• General Provisions, 40 CFR 401
• Oil Pollution Prevention, 40 CFR 112 (CWA § 311)
• Hazardous Materials Transportation Act of 1974, as amended (49 USC § 5100 et seq.)
• General Information, Regulations, and Definitions, 49 CFR 171 Hazardous Materials
• Information and Training Requirements 49 CFR 172
• General Requirements for Shipments and Packaging 49 CFR 173
• Training, 49 CFR Part 172, Subpart H
• National Environmental Policy Act (NEPA) of 1969 (42 USC § 4321 et seq.)
• Resource Conservation and Recovery Act (RCRA) of 1976, as amended (42 USC § 6901 et seq.)
• Hazardous Waste Management System: General 40 CFR 260
• Identification and Listing of Hazardous Waste, 40 CFR 261
• Standards Applicable to Generators of Hazardous Waste, 40 CFR 262
• Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal
Facilities, 40 CFR 264
• Standards for Management of Used Oil, 40 CFR 279.
 Near Real Time Monitoring Systems SOP-PU-0000-R-491(and incorporated references)
 Toxic Chemical Laboratory Analytical Operating Procedures SOP-PU-0000-R-465 (and
incorporated references)
 PCD Site-Specific Laboratory Quality Control Plan (and incorporated references)
 PCD Regulation 385-61-2 Chemical Hygiene Plan (and incorporated references)
 PCD SOP PU-0000-M-486 Chemical Operations (and incorporated references)
 PCD CAIRA Plan (and incorporated references)
3.1 EMS Implementation
The Pueblo Chemical Depot (PCD) has implemented an Environmental Management System
(EMS) to ensure it fulfills the commitments to its Environmental Policy. The scope of the PCD
EMS includes the following PCD and all tenants The EMS is modeled on the specifications
found in the international standard for environmental management in organizations, ISO-
14001:2004. Specific benefits provided to PCD from implementing a formal management
discipline include:
a. The systematic approach to managing PCD’s potential impacts on the environment.
b. Enabling PCD environmental concerns to be managed to accord with mission goals.

3-3
c. Providing documentation of existing processes so that results can be repeated.
Institutional knowledge is captured so it is not subject to personnel flux.
d. Providing a structured approach to identify potential impacts that could otherwise
result in costs, embarrassments, and threats to mission.
e. Having the potential to provide employees with a sense of empowerment that can
translate to enhanced performance on the job.
f. Providing the site with a means to track and measure environmental and
operational performance by instituting metrics.
g. Providing greater discipline and assurance in tracking and analyzing environmental
requirements thus ensuring a higher level of compliance.
h. Allowing PCD to use a risk management approach ensuring the site focuses and
allocates its resources to those that have the greatest probability and worst potential
consequences.
i. Providing for greater sharing of knowledge and responsibilities across all levels and
functions.
j. Supporting reporting under Government Performance Results Act (GPRA).
3.1.1 Summary of Pertinent EMS Concepts
3.1.1.1 Background
Formal Environmental Management Systems (EMS) emerged in the early 1990s to provide
organizations with a proactive, systematic approach for managing the potential environmental
consequences of their operations. Such systems have been widely adopted by industry and
government and have been effective at improving regulatory compliance and environmental
performance.
In April 2000, President Clinton signed Executive Order (E.O.) 13148, “Greening the
Government through Leadership in Environmental Management” that established a 5-year
EMS implementation goal for all Federal Facilities.
3.1.1.2 EMS Model
Although several recognized EMS frameworks exist, most are based on the International
Organization for Standardization’s ISO-14001 EMS standard. As a result, ISO-14001 is the
framework on which organizations most frequently choose to base their EMS, and this has
proven to be the case with U.S. federal facilities.

4-4
1. Phase 1: Planning
The organization identifies how its
operations might harm the
environment, and develops measures
to reduce this harm.
2. Phase 2: Doing
The organization implements the
systemic measures to minimize
harm across all levels and
functions of its operations.
3. Phase 3: Checking
The organization assesses the
effectiveness of the systematic
measures for minimizing both the
potential harm to the environment
and its consequential impacts to
mission.
Phase 4: Acting
Based on its assessment of the implemented systemic measures, the organization undertakes actions
to make system adjustments and to promote continual improvement.
.
The findings of Phase 4 may indicate that adjustments to measures already in place are
necessary or that entirely new approaches are needed to achieve desired environmental
objectives. Output from this phase is fed back into Phase 1 Planning, to make necessary
changes and additions designed to bring the EMS to the desired level of effectiveness. This
system feedback propels the continual improvement of the EMS.
The EMS continually moves through this cycle, fine-tuning its management of those areas of
the organization’s operations that harm the environment. This “continual improvement cycle”
is a fundamental characteristic of the EMS; it allows the system to adapt to the dynamic nature
of the organization’s operations and to remain relevant and viable for its intended purposes.
4. EMS Procedures
Chapter 4 contains PCD’s EMS Procedures. Each procedure describes the methodology used by PCD to execute
various elements of an integrated EMS. The purpose of these procedures is to enable those who maintain the
EMS to understand the requirements of the EMS and to ensure a reliable and consistent execution of those
ACT
Management
Review
CHECK-Checking &
Corrective Action
• Monitoring & measurement
• Non-conformance,
corrective & preventative
action
• Records
• EMS audit
PLAN-Planning
• Environmental aspects
• Legal & other requirements
objectives & targets
• Environmental management
program
DO-Implementation & Operation
• Structure & responsibility
• Training, awareness & Competence
• EMS documentation
• Operational control
• Emergency preparedness & response
Figure 1: ISO14001 EMS Model

4-5
requirements for an effective system. This chapter contains the authorized verbatim version of these procedures.
Copies may be distributed to relevant functions and levels at PCD so that they are available to those individuals
that need to reference them.
This chapter contains the following EMS Procedures:
a. Identifying Significant Environment Aspects
b. EMS Audit Program and Compliance Status
c. Communications
d. Document Control
e. Environmental Management Programs/Operational Controls
f. Emergency Preparedness and Response
g. Legal and Other Requirements
h. Monitoring and Measurement
i. Management Review
j. Nonconformity, Corrective and Preventive Action
k. Objectives and Targets
l. Control of Records
m. Awareness and Competency Training

4-6
4.1 Identifying Significant Environmental Aspects
1. 0 Purpose and Scope
The purpose of this procedure is to identify the significant environmental aspects of the inputs
associated with PCD’s activities, products, processes, and/or services in order to set objectives and
targets for PCD’s Environmental Management System (EMS). The objectives and targets for significant
environmental aspects will then be achieved through the implementation of Environmental Management
Programs (EMPs).
This procedure will be applied to all Inputs within the scope of the EMS that have aspects that are under
the direct control or influence of PCD. It is applied equally to those aspects within the scope of the
EMS at PCD that may originate from external sources.
2.0 Definitions
For definitions meant to help explain terms used throughout this procedure, see Chapter 1, Section 4.
3.0 Procedure
The following approach will be implemented by the EMS Manager, in coordination with Environmental
Management Office (EMO) personnel, to identify the significant environmental aspects associated with
installation Inputs.
3.1 Define/Identify PCD Activities and Inputs
Initial identification of activates will be based on the Depot’s mission. Initial identification of Inputs for
those activities will begin with the EMS Manager identifying every organization that resides at PCD.
They will create a baseline of the Inputs that are within the scope of the EMS and that have the
possibility of interacting with the environment together with their environmental aspects and potential
impacts. Each activity will have at least one Input. Each Input will have one or more aspects associated
with it; likewise, each Input and aspect will have one or more environmental impacts identified.
The baseline list, in spreadsheet format (see Attachment A), will include Inputs that exhibit aspects that
will be further considered for their significance. Any aspects that result from Inputs controlled or
influenced by the installation or tenant will be evaluated for significance. In addition to identifying each
Input and aspect, the baseline list must also include information on the potential environmental
impact(s) associated with each Input.
A number of sources may contain relevant and applicable information that can be used to assist in the
development of the baseline list. These sources include, but are not limited to installation operation
plans; records of emergency response activities; environmental release incidents; environmental impact
statements; range assessments; permit applications; outsourcing documentation; etc.
Additional information regarding environmental aspects will be collected by:
 Brainstorming – Functional managers with a detailed knowledge of PCD’s specific Inputs will
be assembled. This brainstorming team will meet to review PCD’s operations and reflect upon
the likely sources of environmental implications (the aspects). Daily installation Inputs will be
considered first, followed by Inputs that occur on a less frequent basis. Functional managers
assembled for the brainstorming will include at a minimum: Environmental Program managers.

4-7
 Facility Walk Through – A physical walk-through of all areas and operations serves as a visual
“trigger” to ensure that Inputs that should be included in the analysis are not inadvertently
overlooked. The walk-through team will visit each work area within PCD and visually identify
all of the Inputs that contribute environmental aspects, and make any necessary adjustments to
the initial list. After the walk-through, the team will compare its list of “contributors” against the
initial list and make necessary adjustments.
The following Inputs must be included in the baseline list of Inputs:
 Inputs that have obvious regulatory or other requirements.
 Inputs that have visible impacts on the environment.
 Inputs that may not have visible impacts but are known to potentially cause harm to the
environment or human health.
The following Inputs do not need to be included in the baseline list of Inputs:
 Inputs that have minor and temporary impact on the environment.
 Inputs that have been previously declared by qualified, competent experts to be insignificant.
 Inputs that do not satisfy any of the criteria as outlined above.
3.2 Define/Identify PCD Aspects and Impacts
Once the baseline spreadsheet of Inputs and their associated environmental aspects and impacts is
completed, it is provided to all program managers of PCD’s Environmental Management Office (EMO)
for review. The program managers will review this baseline list against existing environmental
programs to determine its accuracy and provide feedback on baseline environmental aspects. The EMO
will also assist the EMS Manager in refining the description of each of the potential environmental
impacts associated with the aspects identified in the baseline list.
The aspects related to inputs that should be cataloged include both those that can be directly controlled
as well as those that can be influenced. It is important to remember that these aspects are only those
from the organization’s Inputs that fall within the scope of the EMS. The determination of aspects is
made by following a sequence of questions:
1) What is the scope of the EMS?
2) What are the Inputs within that scope?
3) What are the aspects of these Inputs?
4) Which of these aspects can be directly controlled?
5) Which of these aspects can be influenced? Those that can neither be directly controlled nor
influenced should not be included in the EMS.
PCD will also identify and address any impacts that may have a cumulative effect. This is especially
important because a large number of different Inputs may produce a common impact. Individually, the
impacts from these Inputs may be low, but in some cases, the cumulative impact may be significant.

4-8
3.3 Identifying PCD Significant Aspects
3.3.1 Having identified the environmental aspects of PCD Inputs, the EMS Manager with assistance
from the IST will evaluate their significance. In general, all aspects that have a legal or other
regulatory requirement will be considered to be significant environmental aspects.
Other factors that bear on significance will consider the severity of environmental, mission, and
community impacts if the aspect were to occur and actually cause its greatest potential negative
consequences. If one of these other factors is given a “high” severity score then the aspect will be
considered a significant aspect irrespective of the existence of any applicable legal or other
requirements. Inputs that score “high” on any of the impact categories will be listed in the
Operational Control section of the EMPs. These other significance factors will be scored using the
following criteria:
1. Positive or Negative Impact to the Environment:
 (3) High: Environmental consequences are serious but reversible over time.
Environmental benefits to ecology or to human health and welfare are moderate.
 (2) Medium: Environmental consequences are noticeable but brief or totally correctable
in a relatively short time period. Environmental benefits to ecology or to human health
and welfare are minimal.
 (1) Low: Environmental consequences are immediately reversible and and/or
administrative, brief and totally correctable. Environmental benefits to ecology or to
human health and welfare are minimal or non-existent.
2. Positive or Negative Impact to Mission Capability:
 (3) High: Interruption of normal mission operation (e.g. line stoppage) is likely and
severe and could result in fines or remediation. Benefit to the organization or mission
capability is substantially improved.
 (2) Medium: Interruption of normal mission operation (e.g. line stoppage) is likely but
recoverable without significant repercussions or the cost of a fine or remediation is
moderate. Benefit to the organization is moderate or mission capability is moderately
improved.
 (1) Low: Interruption of normal mission operation is either unlikely or the consequences
are very slight or easily corrected. Benefit to the organization or mission capability is
minimally improved.
3. Positive or Negative Impact to the Community:
 (3) High: Community would become concerned/aware but not unified in its opposition.
Would produce media coverage and may or may not lead to legal action, political
pressure, or significant embarrassment to PCD.
 (2) Medium: Community may or may not become concerned/aware but would not be
concerned and not likely to result in media coverage, legal action, political pressure or
significant embarrassment to PCD.
 (1) Low: Transparent to community and not a concern, not likely to result in media
coverage, legal actions, or political pressure to PCD.

4-9
3.3.2 The updated spreadsheet (an example sheet is enclosed as Attachment D – Significant Aspects
Identification Table) that documents the significant aspects will be sorted by organization and
distributed to the leaders for review and comment. The last updated spreadsheet can be found in
section 2.3 of this manual.
3.3.3 The EMS Manager will finalize the list and staff it to the Depot Commander for approval.
3.3.4 Once finalized and approved, the list becomes input to the EMS Procedure for Objectives and
Targets.
3.4 Keeping the List of Aspects Updated
This procedure will be applied as necessary to ensure that the PCD EMS identifies all significant aspects
and will be reapplied every 18 months to maintain the currency of the EMS.
4.0 Guidance for Creating the Aspects Spreadsheet
4.1 Consolidate Inputs Within Each Significant Aspect and Determine Need for Subgroups.
The resulting list of significant aspects and their corresponding Inputs may be sub-divided into
subgroups. In general, determining whether or not to split significant aspects into subgroups is
based on management considerations for ease of tracking, for clarity in the assignment of
responsibilities, and for operational considerations including the setting of objectives and targets and
the development and implementation of EMPs. For example, the split may be made along
organizational lines or to highlight a particular source:
• Organizational Differentiation: It may be that one part of the organization contributes a
considerably greater proportion to the significant aspect than all of the other parts combined. In
this instance, it would make sense to have a subgroup for that part of PCD (with the objective to
improve on its performance) and a subgroup for the other parts (with the objective to maintain
their performance).
• Source Differentiation: It may be that there are two (or more) distinct classifications of
sources that contribute to a common significant aspect. For example, painting and degreasing
operations (generating volatile organic compounds) and internal combustion engine operations
(generating Sox, Nox, and CO emissions) may both contribute to the aspect on Air Emissions.
In this instance, it would make sense to split them into two subgroups since each would have a
different strategy to improve its own performance.
4.2 Evaluating New/Modified Inputs
The EMO Director and/or EMS Manager will attend Production Planning Meetings (PPM). PPM
meetings discuss new and changing functions within the Directorate for Maintenance. An additional
method of notification that may be utilized is whenever a new Input is initiated, or an existing Input
is modified, the relevant organization shall notify the EMS Manager by routing information on the
new or modified Input to the Environmental Division.
The NEPA Coordinator in EMO will also route pertinent information on new or modified projects to
the affected EMO staff for an evaluation to ascertain if any significant environmental aspects have
been introduced and/or modified, and to make necessary adjustments in the EMPs.

4-10
Newly identified significant aspects will be added to the EMS in accordance will all applicable EMS
procedures.
4.3 Evaluating Aspects from External Sources
This procedure is also applied to Inputs that originate from external sources (e.g., suppliers).
Significant environmental aspects at PCD that originate from such sources shall be managed like all
other significant environmental aspects. PCD may take steps to notify those external parties over
which it has some influence to mitigate any aspects that may reasonably be mitigated at the source.
Where no such influence exists or where mitigation at the source is infeasible, PCD will address
such aspects within its own EMS.
5.0 Records
The PCD EMS Manager will keep and maintain the following records that result from this procedure
(the information may be organized into separate lists or into one or more tables to facilitate access and
presentation):

4-11
Attachment A: Operational Inputs and Associated Aspects and Impacts (sample)

4-12

4-13
Attachment B: Significant Environmental Aspects List
1. Air Emissions (ODS (CFCs in building chiller systems), VOCs (fugitive emissions from vehicle
fueling operations, chemical cleaning, parts washing, painting, etc.), criteria pollutants (machinery
operations, vehicle operations, etc.), dust, particulates, odors)
2. Solid Waste Generation (other)
a. Paper/Cardboard Generation
b. Wood Pallet Generation
c. Scrap Metal Generation
d. Tire Generation
3. Hazardous/Regulated Industrial Waste Generation (laboratory or degreasing solvents, hazardous
batteries, empty chemical containers, used oil, paint filters)
4. Universal Waste Generation (waste paints, blast media, florescent lights, batteries, etc.)
5. Chemical Spills/Leaks to Surface or Ground Water (fuel, hydraulic leaks, POL, storage tank
leaks, perchlorate, cadmium, other heavy metals etc.)
6. Toxics Releases (TRI and TIER 2 inventories)
7. PCB Releases
8. Asbestos Releases
9. Lead Based Paint Releases
10. Pesticide Applications (grounds maintenance, pest control)
11. Liquid Discharges (point and non-point) to surface and/or ground waters [(industrial wastewater
contributions from painting operations, metal etching/plating, X-ray activities, vehicle maintenance
areas), sewage, wash-racks, air dryers, and storm-water]
12. Electricity Consumption (high electricity use operations)
13. Fuel Consumption (petroleum products, natural gas, and other alternative fuels)
14. Water Consumption (high water use operations)
15. Ecological Disturbance (NEPA, hydrological alteration, vegetation alteration, habitats, wetlands,
threatened and endangered species, invasive species, etc.)
16. Cultural Resource Disturbance (historic properties, graveyards)
17. Generation of Noise or Nuisances (testing operations, vehicle operation, vibration, visual
impairment)
18. Soil Erosion (construction activities and ground clearing)

4-14
Attachment C: Sample Environmental Impacts
 Toxics contamination or addition to air, land, waterway
 Reduced visibility
 Air pollution (smog, acid rain, dust, visual impairment)
 Human health impact
 Landfill depletion
 Resource depletion
 Soil contamination
 Groundwater contamination
 Surface water contamination
 Hazardous material damage
 Biological material damage
 Ecological damage
 Ozone depletion
 Greenhouse gas release
 Habitat alteration
 Introduction of non-native species
 Pesticide damage
 Cultural resource property-damage
 Sedimentation of water courses
 Increased runoff / stream flow
 Watershed alterations
 Soil compaction
 Wind erosion
 Water erosion
 Loss or damage to threatened and endangered species
 Noise damage
 Vibration damage
 Heat damage
 Radiation damage
 Odor nuisance
 Nuisance to community
 Loss of indigenous species

December 2011 Draft UNCONTROLED IF PRINTED PCD EMS Manual
4-15
4.2 PCD EMS Audit Program
1.0 Purpose and Scope
The PCD EMS Audit Program is implemented to ensure the organization allocates resources, provides
qualified auditors, plans the execution of audits and otherwise arranges for the efficient and effective
conduct of internal EMS audits in support of the EMS. Internal EMS audits support the EMS and
provide a periodic check of its status so that management can make decisions regarding its continuing
suitability, adequacy and effectiveness. Internal EMS audits also assess conformance to the
requirements of the ISO-14001:2004 standard and are used to verify that the organization periodically
does compliance status checks. The PCD Audit Program is based on the ISO-19011 standard.
2.0 Definitions
3.0 Approach
3.1 Audit Program Chart: International Organization for Standardization. (Final Draft 2002). ISO-
19011: Guidelines for quality and/or environmental management systems auditing. ISO/FBIS 19011:
2002(E).
Authority for the audit
program
Establish the audit program
• Objectives and extent
• Responsibilities
• Resources
• Procedures
Implementing the audit Program
• Evaluating auditors
• Selecting audit teams
• Directing audit activities
• Recording
Monitoring and reviewing
the audit program
• Identify opportunities for
improvement
Competence
of Auditors
Improving the
Audit Program Audit
Activities
P
L
A
N
D
O
C
H
E
C
K
A
C
T
3.2 Audit Program Manager Responsibilities - The EMS Manager also acts as the Audit Program
Manager for internal EMS audits and internal compliance audits. The EMS Manager has the following
responsibilities:

4-16
a. Ensures adequate resources have been allocated in relevant budgets for the conduct of planned
internal EMS audits.
b. At the beginning of each fiscal year, plans the audit strategy (e.g., functions to be audited,
elements to be audited, schedule of audits, team members for each audit, lead auditor for each
audit, etc.).
c. Ensures sufficient auditors will be available and that they remain competent through further
training or other means of maintaining competency.
d. Stores and manages all documentation from previous audits (e.g., audit reports, records of
corrective actions, etc.).
e. Maintains Audit templates and checklists of criteria for use by the audit teams.
f. Evaluates auditors and makes decisions on qualifying additional individuals as competent
internal auditors.
g. Works with the lead auditor assigned to a given audit to establish the objectives for that audit and
to ensure that the proper resources and information are available to conduct the audit.
h. Ensures that the audit team conducts and completes the audit.
3.3 Frequency of EMS Audits
Internal EMS audits shall be scheduled on the basis of need as reflected by the importance of Inputs
or the results of previous audits, but not less than annually, in order to verify that the system is
implemented and functioning as expected. An individual audit may be limited to a sampling of EMS
elements or areas and can be both random and/or focused on certain Inputs based on their
importance and/or results of previous audits. The audit program manager will decide on the strategy
to be pursued in the audit at the beginning of each fiscal year.
3.4 Scope of EMS Audits
On an annual basis, internal EMS audits assess all operations and facilities described within the
scope of the EMS to determine conformance for these operations and facilities against the
requirements of ISO-14001:2004, and the organization’s internal performance objectives. Every
organization will be audited at least once annually. Depending on the results of previous audits, the
EMS Manager may opt to conduct one yearly audit or a series of audits that focus only on specific
elements.
3.5 Selection of Audit Team
The audit team shall be designated by the Depot Commander and shall consist of personnel that have
received internal EMS auditor training and are deemed competent to conduct such audits. The PCD
EMS Manager is responsible for overseeing the EMS Audit Program. He or she is also responsible
for selecting the lead auditor for a given audit. The designated lead auditor is responsible for
ensuring that the audit team conducts and completes the audit as planned. The Audit Program
Manager shall not be a member of the audit team.
The EMO Director may also bring in an outside contracted audit team to perform an internal audit or
periodically, as needed, to get a fresh perspective and overview of whether the EMS is meeting
established goals and functionality.
3.6 Internal Audit Procedure

4-17
The internal audit will be conducted in accordance with the Internal EMS Audit Procedure (for
details, please refer to that procedure below). EMS internal audits shall be conducted against pre-
established audit criteria (see below). The audit criteria may be based on the sample audit criteria
provided below which can be tailored to suit the specific needs and goals of the organization based
on input from the EMS Manager and the lead auditor.
Audit criteria shall consist of questions based upon the specified arrangements for the EMS, and
shall be designed to elicit evidence of conformity with the organization’s EMS requirements. The
focus of the EMS audit is to ascertain whether the EMS has been effectively implemented and is
functioning in accordance with established PCD-specific arrangements.
Audit findings must be based on objective evidence that is properly corroborated and authenticated.
(Auditors shall avoid reaching conclusions on the basis of hearsay or opinion.)
3.7 Compliance Status
The EMS audit may also be used to verify that the compliance status has been established as
arranged. The compliance status may be based on the results of a recent internal compliance audit
(EPAS) that may have occurred. All internal compliance audits will utilize the most current EPAS
Team Guide. PCD will rely on the internal EPAS compliance audits to ascertain its compliance
status. Ongoing compliance checks will be conducted via routine walk-around inspections
performed by the environmental division personnel.
The internal EMS auditor shall ascertain that the organization has previously conducted a
compliance status check as required by the ISO-14001:2004 standard.
3.8 Corrective Action
After conferring with the EMS Manager, the appropriate area or functional manager will address
findings within a specified number of days by developing corrective actions which will be included
in the summary response to the corrective action request.
If a nonconformity relates to the EMS itself, the EMS Manager will have the primary responsibility
to apply the corrective and preventive actions. In this instance, the audit team ensures that the
corrective and preventive actions have been completed when the next scheduled audit is conducted.
3.9 Preventive Action
Preventive action is undertaken to avoid repetition of the nonconformity in other areas or functions
of the organization that may have similar vulnerabilities that caused the original non-conformity. It
is the responsibility of the EMS Manager to initiate preventive actions as specified in the EMS
procedure for Nonconformity, Corrective and Preventive Actions. The execution of preventive
actions may be recorded in the Corrective Action Request report or it may be documented
separately.
For more detailed information, refer to the organization’s procedure for Nonconformity, Corrective
and Preventive Action.
3.10 Follow-Up

4-18
At the conclusion of the audit, the audit team will determine whether any findings require follow-up
after the corrective and preventive actions are applied. This will be based upon the frequency,
severity, and/or risk of continued or potential nonconformities, as well as on whether the finding was
either a major or critical audit finding.
3.11 Closing the Audit
EMS audits are closed when the audit team leader establishes that the corrective and preventive
actions have been completed.
3.12 Input to Management Review and to Next EMS Audit
The Audit Report and actions taken to address findings will be inputs to the Management Review.
For more detailed information on the purpose and content of the Management Review, please refer
to the Management Review Procedure. (The audit report, corrective action requests and records of
corrective and preventive actions will also be available to auditors that will be preparing the next
scheduled audit.)
3.13 Audit Process Documentation
Documentation that result from the conduct of an EMS audit may include the items listed below.
The audit program manager provides proper templates for these items to the audit teams for their use
on audits:
i. Audit Plan
j. Audit Criteria
k. Internal Audit Report
l. Detailed Audit Findings and Conclusions
m. Completed corrective action.
3.14 Audit Resources
PCD management should be able to demonstrate that it has committed to allocate the resources
necessary to support the continual improvement of the EMS by providing budget and staff resources
necessary to maintain this EMS Audit Program. In addition, it should be able to show that auditor
training will be provided for the audit team as necessary and that contracted resources may also be
utilized, if necessary, to perform internal audits.
Attachments to Audit Program and Compliance Status:
1. Audit Work Flow
2. Audit Procedure
3. Audit Criteria

4-19
Attachment 1 to Audit Program and Compliance Status: Audit Work Flow
to audit)
Attachment 2: Audit Work Plan
Initiating the Audit
Appointing the audit team
leaderDefinition of objectives, scope and
criteriaDetermination of the feasibility of the
auditEstablishing the audit
teamInitial contact
with the
audite
e
On site Audit
ActivitiesConducting opening
meetingCollecting and verifying
informationGenerate audit
findingsCommunicating during
the auditPreparing audit
conclusionsConducting closing
meeting
Reporting on the Audit
Audit report
preparationReport approval and
distributionRetention of
documents
Audit Completion
Audit Follow-up
Initiating the Audit
Appointing the audit team
leaderDefinition of objectives, scope and criteria
Determination of the feasibility of the
auditEstablishing the audit team
Initial contact
with he
Onsite Audit
ActivitiesConducting opening meeting
Collecting and verifying
informationGenerate audit findings
Communicating during the audit
Preparing audit conclusions
Conducting closing meeting
Reporting on the Audit
Audit report
preparationReport approval and
distributionRetention of documents
Audit Completion
Audit Follow-up

Document
Review of relevant management
documents and records and
determination of their adequacy
Audit Planning
Onsite
Activities
Audit
Completion
Preparing for Onsite Audit
Preparing the audit plan
Audit teamwork assignments
Preparation of work documents




4-20
Attachment 2 to Audit Program and Compliance Status: Internal EMS Audit Procedure
Purpose and Scope
This procedure specifies the requirements for performing Internal Environmental Management
System (EMS) Audits at the Pueblo Chemical Depot (PCD). These audits are a part of the PCD
EMS and are conducted periodically to ascertain that the EMS is properly implemented and
continues to conform to planned arrangements for environmental management, including the
requirements of ISO-14001:2004.
Scope
An individual audit may be limited to a sampling of EMS elements or areas within the PCD, and can
be both random and/or focused on certain Inputs based on their importance and/or results of previous
audits.
Definitions
Approach
Responsibilities:
The audit team shall be designated in writing and shall consist of personnel that have received
internal EMS auditor training and are deemed competent to conduct such audits. The PCD EMS
Manager is responsible for overseeing the EMS Audit Program. He or she is also responsible for
selecting the lead auditor for a given audit. A designated auditor will be responsible for ensuring
that the audit team conducts and completes the audit as planned.
Audit Planning:
Each audit requires an audit plan (see attached Audit Plan template) that is prepared by the lead
auditor for that audit. The audit plan addresses the following preparatory matters:
 Audit scope and objectives;
 Audit criteria to be applied;
 Contacts and coordination with the auditee(s);
 Audit dates, times, and other logistics;
 Review of previous audits, records, and descriptions (e.g., programs, operations, etc.);
 Protocol for conducting the audit (e.g., interviews, access, coordination, safety, resolution of
findings, etc.); and
 Responsibilities for writing the audit report and for follow-up actions.
Requirements:
 Individuals on the audit team must receive internal auditor training and be designated as
competent to conduct internal EMS audits;
 EMS audits will be conducted against pre-established audit criteria;
 The audit criteria shall be developed jointly by the entire PCD audit team, and approved by
the EMO Director;
 Audit criteria shall consist of questions based upon the specified arrangements for the EMS,
and shall be designed to elicit evidence of conformity with ISO-14001:2004 and PCD
arrangements for environmental management.

4-21
 The focus of the EMS audit is to ascertain that the EMS has been effectively implemented
and is functioning in accordance with established arrangements; and
 Audit findings must be based on objective evidence that is properly corroborated and
authenticated. (Note: Auditors should avoid reaching conclusions on the basis of hearsay or
opinion.)
On-Site Audit Process:
 EMS audits will be conducted primarily through interviews with personnel;
 EMS audits may include sampling. For example, compliance data may be sampled to
ascertain that compliance programs are achieving their intended objectives;
 The EMS auditors may also rely on records for information related to the functioning of the
EMS and its objectives and targets;
 The EMS auditors may also rely on observations of operating conditions to gauge
environmental status and conditions, where appropriate and efficacious;
 The audit team will conduct opening and closing meetings with responsible management of
the areas being audited;
 The audit team will document corrective actions. Responsibility for corrective actions will
reside with management in the area where the findings occurred. If a corrective action
relates to the EMS itself, the PCD EMS Manager will have primary responsibility to arrange
for the correction to be made. The audit team validates that the corrective and preventive
actions have been completed by the auditee.
Regulatory Compliance Status:
The regulatory compliance status at PCD is established periodically through the external EPAS
audits, internal compliance audits, routine walk-around inspections, state audits, EPA audits and
other external audits.
Audit Report:
When the audit is complete, the audit team will complete the audit details. After audit details have
been completed they will be available to the PCD EMS Manager and the manager for the area
audited.
Closing the Audit:
The audit team will monitor the auditee’s completion of corrective and preventive actions for a
proper closing of the audit. The EMS audit is closed when the audit leader establishes that the
corrective and preventive actions have been accomplished.
Input to Management Review:
The results of the audit and the status of the corrective actions are to be presented at the next
scheduled Management Review meeting.
Records
Records generated by this procedure are maintained by EMS Program Manager and include the
following information:
1. Audit planning information
2. Audit criteria
3. Audit findings and conclusions
4. Completion of corrective and preventive actions.

4-22
Attachment 3 to Audit Program and Compliance Status: Audit Criteria, ISO-14001:2004
4.2,1 Environmental Management System Audit Criteria ISO 14001:2004
Purpose
The purpose of this document is to provide the criteria for the internal audit of the Environmental
Management System (EMS) implemented at PCD as required by Executive Order 13423.
Findings categories:
Major nonconformity finding: A significant number of minor findings against one element of the EMS
or a completely missing element.
Minor nonconformity finding: A single nonconformity against an element of the EMS.

4-23
Sample Audit Checklist

4-24

4-25

4-26

4-27

4-28

4-29

4-30

4-31
4.3 PCD EMS Procedure for Internal and External Communications
The purpose of this procedure is to establish a reliable and consistent process for addressing and
documenting communications pertinent to the Pueblo Chemical Depot (PCD) Environmental
Management System (EMS). Specifically, this procedure is used:
 To enumerate the internal communication tools and processes for communicating EMS-related
information between levels and functions inside PCD;
 For receiving, documenting and responding to relevant information and requests from external
interested parties; and
 To communicate information and/or requirements related to the identified significant environmental
aspects of goods and services (used or outsourced at PCD) to suppliers and contractors in accordance
with the requirements of PCD’s EMS.
This procedure is applied to all internal and external communications regarding the PCD EMS,
including communications initiated by PCD as well as communications from PCD in response to
external requests for information.
2.0 Definitions
3.0 Approach
3.1 Internal Communications:
PCD utilizes several “information tools” as a means of maintaining a high level of information flow
between all levels of the Depot’s structure. These include: Intranet web sites, e-mails, telephone,
memorandums, recurring meetings, etc. All personnel are strongly encouraged to use these methods to
exchange ideas, discuss problems and ask questions from supervisors and other Depot members. Major
topics of internal communication include, but are not limited to:
 Environmental policy, objectives, and targets;
 Environmental roles and responsibilities;
 Environmental regulatory requirements;
 Environmental performance compared to objectives and targets;
 Environmental policies and procedures; and,
 Hazards and emergency response procedures.
The Depot Commander is responsible for communicating the installation’s environmental policy. The
proponent for all other internal environmental communications is the Environmental Division.
However, dissemination of environmental information to all installation personnel is the responsibility
of all levels of management. Conversely, all installation personnel are encouraged to provide feedback
through their appropriate chain of command on issues that could impact the environmental performance
of the installation.
1. The following actions promote internal communication regarding the PCD EMS:

4-32
 The PCD Environmental Policy will be communicated to all PCD personnel. A hardcopy of
the most current policy statement will be posted on all “official” PCD message boards
 EMS Training:
o Awareness Training – All PCD personnel will receive EMS Awareness Training. (New
personnel will receive this training during the New Employee Orientation.)
o Competence Training – For personnel whose work may involve significant
environmental impacts, PCD will evaluate competence and deliver training targeted to
the person’s job function, if that is deemed necessary to upgrade his or her skills.
o Outreach campaign – As necessary, EMS outreach efforts will be undertaken to promote
the EMS awareness (e.g., Earth Day activities, etc.).
o Contractors working on the depot for more than 6 months will be required to attend an
EMS Awareness training session. If their work may involve a significant impact, the
contractor will evaluate competence and deliver training targeted to the person’s job
function, as appropriate.
3.2 External Communications:
1. Consistent with its commitments in the Environmental Policy statement, PCD will communicate
relevant information regarding its EMS. Specifically, PCD will take the following actions under
its EMS:
 Make its Environmental Policy available to the public via the Environmental Monitor
quarterly news letter; the AQWA/PCD Web Site or upon request;
 Report all environmental information required by regulation to the appropriate authorities;
and
 PCD has considered the external communication of its significant environmental aspects and
will do so fully as required by law.
2. Regarding non-regulatory inputs from external interested parties, PCD has instituted the
following process:
 All written, non-regulatory external inquiries concerning environmental performance, are
received or routed to the PCD Public Affairs Office (PAO). A determination of Freedom of
information Act (FOIA) is made. If the inquiry is determined to be FIOA then it is
forwarded to the FIOA Office for processing.
 The SME provides documentation and generates the OPSEC review forms for staffing the
response prior to release from the Depot.
 The PAO shall ensure that the response is timely.
 The EMS Manager and Environmental Program Managers will consider all external
communications when establishing and reviewing environmental objectives and targets for
the EMS and will initiate any necessary changes to the EMS.
 All responses to inquiries from members of Congress will be coordinated through PCD Legal
Office and staffed through PAO for Depot Commander’s signature.
 PAO prepares responses to inquiries from the media will be coordinated through the PAO
and routed through the Legal Office and the Office of the Commander.

4-33
3. Regarding regulatory written correspondence and requests, PCD has instituted the following
process:
 All regulatory requests concerning environmental performance are received or routed to the
EMO Director.
 The EMO Director may obtain input or task the appropriate EMO Program Manager to
prepare a response to the regulatory body.
 The EMO Director approves the response, and either signs it, or routes it for appropriate
signature either to the Director of Public Works, Legal Office or to the Depot Commander.
 Formal communications will be entered into the EISIS system or maintained in the EMO
master files.
3.3 Communications with Suppliers and Contractors:
1. PCD will communicate the following information to appropriate suppliers and contractors,
including contractors used for outsourcing:
 PCD is concerned about environmental issues and desires to conduct its business operations
in an environmentally sound manner.
 Relevant significant aspects will be communicated to contractors (including those used for
outsourcing) and suppliers through the bid package. It will also be applied to contractors
working onsite at the depot for more than 6 months.
 PCD has implemented an EMS, which is based on ISO-14001:2004.
 PCD expects its suppliers and contractors to provide, at the same quality and price, products
and services that have the least environmental consequence of all available options.
 Where a supplier’s product is causing a significant environmental aspect at PCD, PCD will
communicate to that supplier that wherever possible, they should select the available option
that minimizes the potential environmental impact of that product.
2. Where a supplier or contractor is supplying goods or services associated with significant
environmental aspects, the affected PCD manager will work with the appropriate procurement
representative to inform that supplier or contractor of applicable procedures and requirements to
mitigate, minimize, or otherwise control the potential environmental impacts associated with
those significant environmental aspects. This will also be applied to contractors used for
outsourcing.
3. Communications with suppliers and contractors shall be documented in accordance with PCD
procurement procedures.
4.0 Records
Records generated from the execution of this procedure will be maintained in electronic form and in
hard copy and include:
 Records of submissions to regulatory authorities;
 Records of environmental reports to the public if any;
 Copies of requests and responses to external parties;
 Copies of sent and received communications from suppliers and contractors.

4-34
4.4 PCD EMS Procedure for Document Control and Documentation
The purpose of this procedure is to provide a standard method for controlling documents that support the
operation of the Pueblo Chemical Depot Environmental Management System (EMS). This procedure
provides instructions, and assigns responsibilities for the establishment, review, authorization, issue,
distribution, and revision of controlled documents and records.
This procedure applies to the creation, revision, approval, distribution and version control of all
documents associated with the EMS.
2.0 Procedure
Personnel with specific EMS document responsibilities will ensure that documents are current, available
to personnel that need them, and are removed when they no longer apply or have been rendered obsolete
by updated versions.
Controlled documents, such as SOPs or management plans, are accessible through the intranet website.
Printed copies of these controlled documents will be marked with the statement “Controlled Document,
Uncontrolled if Printed.” Further detail of this procedure for approval and version control is
supplemented by specific requirements.
Other documents and records may exist outside the system and are not considered official controlled
documents. These documents may exist as information transport tools to final record locations and/or
may be developed and used for personal use only.
3.0 EMS Documentation
EMS documentation provides a standardized structure for organizing PCD’s EMS programs,
procedures, work instructions, and records. The structure of the documentation is as follows:
 The EMS Manual - describes the core elements of the management system, including their
interrelationships. The manual provides an overview of the EMS. It refers to, and cross-
references, related documentation such as EMS Procedures, and EMPs. EMS Procedures detail
specific EMS requirements and the roles, responsibilities and authorities to fulfill the
requirements. As appropriate, procedures reference related documentation such as EMPs and
work instructions. EMPs included in chapter 5 of the manual are included for reference only and
will be replaced with the most recent version only when the EMS manual is updated. These
procedures and programs are applicable to the operations at Pueblo Chemical Depot. The EMS
Manual details requirements and guidelines for implementation. (The EMS Manual is available
in electronic media at relevant workstations).
 Depot Level Documents – PCD Regulations, Commander’s Policy Statements, Pamphlets, and
other directives published at the depot level that supports the EMS Manual requirements and
guidelines are located on the Depot Intranet.

4-35
 Policy and Instructions (P&Is), Standing Operating Procedures (SOPs), Operating
Instructions (OIs) – Internal organizational Policy and Instructions, Standing Operating
Procedures, and other Operating Instructions.
 EISIS Database – the following EMS documentation will be maintained in the EISIS Database:
o List of environmental aspects associated with PCD Inputs
o Routine Recurring tasks outlined in the EMPs
o EMS records not managed by Environmental Program Managers
o Training information
4.0 Records

4-36
4.5 PCD EMS Procedure for Environmental Management Programs and
Operational Controls
The purpose of this procedure is to establish a reliable and consistent approach for creating and
documenting the Environmental Management Programs (EMPs) associated with the Pueblo Chemical
Depot (PCD) Environmental Management System (EMS). EMPs provide the guidance, information,
and references necessary for the efficient and effective accomplishment of the objectives and targets that
are set for the PCD EMS. PCD documents its EMPs in order to avoid confusion and ambiguity about
what needs to be done and who is responsible for doing it. This EMS procedure also provides guidance
for applying Operational Controls (OCs) to PCD’s Inputs with the potential for significant
environmental impacts.
PCD’s EMO staff applies this procedure to develop and document the EMPs that they create, update,
and implement to achieve the objectives and targets of the PCD EMS. Objectives and targets are set
through the execution of the EMS Procedure for Setting Objectives and Targets.
2.0 Definitions
3.0 Approach
PCD uses the EMP Template (See attached EMP Template) as a guide to structure existing and new
EMPs. The EMPs also demonstrate the different elements of the EMS and their interaction. Existing
PCD programs are periodically reviewed to ensure they contain the programmatic information elements
shown in the EMP Template. Once completed, the EMP templates are reviewed by the Environmental
Management Office Director. EMPs will be reviewed and updated if needed by each program manager
at least one time a year and are available to the Office of the Commander. The official version of the
EMPs will be maintained by Environmental Management Office.
4.0 Records
EMPs generate a variety of EMS records. In most instances, the EMP template itself serves as a record:
1. The previous 3 years of completed EMP templates (Starting May 2006);
2. Records that reflect the status of objectives and targets as measured during the course of
program implementation, where applicable;
3. Records that reflect the assignment of roles and responsibilities, when used;
4. Records that reflect the allocation of other resources, when used;
5. Records other than the EMP that substantiate declarations of employee competency, when
used;
6. Records of maintenance performed on operational controls;
7. Records of any Corrective Actions taken in the event of interrupted or failed controls;

4-37
8. Records of operational controls that were communicated to external sources of goods and
services; and contractors working on site or doing outsourced work and
9. Records that demonstrate the functioning of operational controls, either ongoing or periodic
depending on what is appropriate and actually implemented.

4-38
Example Environmental Management Plan (EMP)
Significant Aspect: Tracking Number
Department/Area(s): Date:
Objective: Process/Activity:
Potential Impacts: Target:
Legal and Other Requirements:
Task Responsible
Party
Schedule/Resources Key Characteristics/Performance
Criteria
.
Approvals: Submit to the Environmental Quality Control Committee (EQCC) for review and approval.

4-39
Guidance for Completing the EMP Template
This guidance complements the information in the EMS Procedure for creating environmental
management programs (EMPs) and their associated operational controls (OCs). Specifically it provides
guidance for completing the EMP template which is designed to capture programmatic, management
summary information for a more structured, consistent and documented management of environmental
programs at PCD. The EMP template is designed to not only to incorporate all the main elements of the
EMS and document their interaction, but actually be a usable tool in managing PCD’s Significant
Environmental Aspects.
Field 1. Significant Aspect: The aspect listed here may be generic (e.g., air emissions), it may be by
criteria (e.g., particulates), or it may be specific to a function or Input (e.g., CFC emissions from
refrigeration). The aspect needs to be as specific as is required to manage it efficiently and
effectively. The degree of granularity and specificity in categorizing aspects is therefore dependent
on how they will be managed and on how best to communicate that information in the EMP
documentation. It is not useful to aggregate dissimilar aspects when their management requires
different protocols and controls. Such agglomeration may result in lack of clarity and increase the
likelihood of mismanagement of the environmental aspect in question.
Field 2. Tracking Number: This designator is a unique number used by EMO to control document
version as a means to ensure that only the authorized and currently valid version is in use.
Field 3. Department/Area(s): This is the name by which this program will be known in the
organization.
Field 4. Date: This is the date when the document was last revised. Such information may be of value
to different users of the EMP. It may be used, for example, to archive previous versions of the EMP.
Field 5. Objective: The objectives listed here are those that the organization has set for itself with
respect to the environmental aspect that is treated in this EMP. The number of the objective is set by
the EMS manager and should remain the same. If the number of the objective changes the EMS
manager will notify all program managers via e-mail. (See EMS Procedure for Setting Objectives
and Targets for an explanation of what they signify.)
Field 6. Process/Activity: The information recorded here should signify the reason why each impact is
“significant” (e.g., regulation; mission impact; environmental impact). It should provide sufficient
detail to inform prospective users on the full consequences of each individual impact. This is
valuable insight that underlies the importance of the EMP and should not be assumed to be
“obvious” to newcomers that are not familiar with the issue. For example: Noise is a significant
aspect because it is regulated and because complaints from the adjoining community could cause a
shutdown a major operation at the Depot.

4-40
Field 7. Potential Impacts: These are the potential impacts enumerated through the execution of the
EMS Aspects Identification Procedure. Their documentation within the EMP allows for a fuller
description of these potential impacts.
Field 8. Target: : The targets listed are those that have been set by the organization to achieve the
objectives specified. Once a target has been completed the word completed should follow the target
where one would normally identify the target date of completion. Once this completed target has
remained for one update it should then be deleted from the EMP. This will insure that a record of
compulsion will de documented on the EMP.
Program indicators should be specified for all the targets. Program indicators should have been
selected during the setting of objectives and targets while the nature of the objectives and targets are
fresh on the minds of the EMO Program Managers. EMP leads should ensure that a complete list of
program indicators that correspond to the targets is shown in this field; normally, there is a one-to-
one correspondence between them.
Field 9. Legal and Other Requirements: This field contains details on the applicable legal and other
requirements derived through execution of the EMS Procedure on Legal and Other Requirements.
These are the legal and other requirements that apply to the Inputs that exhibit the environmental
aspect in question. The level of detail for legal and other requirements should be as complete as
possible. That detail is necessary if the organization expects to maintain compliance with legal and
other requirements. This field should, therefore, list all the detailed legal and other requirements that
apply to this environmental aspect for the Inputs listed in field 11 below.
Field 10. Task: This field describes what controls are to be implemented to achieve target goals of the
EMP.
Field 11. Responsible Party: This field contains the name or names of organizations within PCD that
have been given the responsibility to operate or otherwise implement the operational controls.
Field 12. Schedule/Resources: This field sets forth the date the target goal is to be achieve and any
resources needed.
Field 13. Key Characteristics/Performance Criteria: The information in this field of the EMP
should be as detailed as necessary to ensure effective control of the Inputs that exhibit the environmental
aspect in question so as to prevent that aspect from occurring.
Field 14. Approvals: The approving authority for PCD is the EQCC for all EMP’s.

4-41
4.6 PCD EMS Procedure for Addressing Emergency Preparedness and Response
The purpose of this procedure is to describe the process to identify potential emergency situations and
potential accidents and how Pueblo Chemical Depot will respond to them, and prevent or mitigate
associated adverse environmental impacts. This procedure specifies those EMS requirements that
pertain to the environmental consequences of an incident or emergency. It does not address itself to
other consequences that may result from an incident or emergency. An incident or emergency involves
more than a nonconformity in the EMS or a minor spill or release. For purposes of the EMS,
nonconformities and minor spills or releases are corrected through the provisions of Pueblo Chemical
Depot Procedure for Nonconformities.
2.0 Definitions
3.0 Procedure
3.1 General: Despite Pueblo Chemical Depot’s best efforts, incidents and other emergency situations
can occur. Effective emergency preparation and response can reduce injuries, prevent or minimize
environmental impacts, protect employees and neighbors, reduce asset losses, and minimize mission
impacts. Pueblo Chemical Depot has developed numerous plans that address various types of incidents
and emergencies. These plans form the basis for Pueblo Chemical Depot emergency preparedness and
response actions. The operational requirements that have been implemented to address hazardous
substance spills and/or releases are provided in the Pueblo Chemical Depot Installation Spill
Contingency Plan (ISCP). Responses to emergencies such as fires, floods, and earthquakes are managed
through the National Incident Management System (NIMS) and the Incident Command System (ICS).
See below for additional plans.
3.2 Responsibilities: All Pueblo Chemical Depot personnel have a responsibility to prevent and
minimize incidents and other emergency situations. Emergency preparedness and response can involve
multiple organizations on and off the installation. Specific responsibilities include:
EMS Manager: Ensure all appropriate environmental plans (see section 2 .0) are prepared and current,
and are maintained in accordance with Pueblo Chemical Depot’s document control procedures.
On Scene Coordinator: Has overall responsibility for leading an emergency response action. The On-
Scene-Coordinator will be the Chief, Pueblo Chemical Depot Fire Department.
3.3 Emergency Preparedness: All required plans will be reviewed and updated, as appropriate, at least
every 18 months by the plan POC. Plans will be reviewed to ensure they meet all current regulatory
requirements and to identify changes on the installation that may affect plan execution. The review
should include plan attachments, such as contact names, phone numbers, maps, facility floor plans and
material safety data sheets (MSDS). Emergency preparedness procedures will be exercised and tested

4-42
through drills and tests in accordance with regulatory and plan requirements, and to ensure all mitigated
actions are considered and implemented. Plans will be readily accessible to potentially affected
personnel and hard copies posted in high risk work areas.
3.4 Emergency Response: Responses to all accidents and emergencies will be conducted in accordance
with the procedures specified in the applicable response plan.
4.0 Records
This procedure generates the following EMS records. Items 1, 2, and 3 will be maintained as part of the
plan:
1. Records of incidents and emergencies that can result in environmental consequences;
2. Records of exercises and associated reviews; and
3. Records that indicate changes to the ISCP as a result of exercise reviews.

4-43
4.7 PCD EMS Procedure for Legal and Other Requirements
The purpose of this procedure is to ensure that appropriate site personnel are aware of all legal and other
regulatory requirements that are applicable to the environmental aspects of Pueblo Chemical Depot’s
(PCD) Inputs. Information on legal and other regulatory requirements is incorporated into the
installation’s environmental management system (EMS) and will be considered, with other factors, to
set objectives and targets.
The listed environmental aspects that were documented through the use of PCD’s EMS Procedure for
Identifying Significant Environmental Aspects provide the base for identifying the legal and other
requirements that are applicable and relevant to PCD’s environmental aspects.
2.0 Definitions
3.0 Procedure
3.1 Identification of Existing Requirements
The EMO EMS Program Managers (EPMs) will obtain and review the regulations pertinent to all
environmental aspects identified within their area of responsibility. The EPMs may do this by
accessing the internet, subscribing to free email notification services, attending periodic training,
reading trade or technical journals and environmental newsletters, consulting with other
environmental professionals (other installations or private industry), hiring consultants, requesting
assistance from colleagues in EMO, or requesting input from the Legal Office on regulatory
information associated with aspects. Any of these methods and sources of regulatory information
are suitable as long as they provide a high degree of certainty regarding the regulatory implications
of each environmental aspect identified by PCD’s EMS Procedure for Identifying Significant
Environmental Aspects. Other sources, means and methods for identifying legal and other
requirements include, but are not limited to the following:
 Daily Federal Register or Federal Register Summary,
 Code of Federal Regulations,
 Colorado Department of Health and Environment (CDPHE) website,
 Defense Environmental Information Exchange (DENIX) Web site,
 Bureau of National Affairs database, and
 Hazardous Technical Information System Bulletins.
 Correspondence pertaining to enforcement actions, Notices of Violation (NOVs), consent orders,
and findings from internal compliance audits.
The compiled list of legal and other requirements must be maintained in a format that is readily
updatable to allow for the insertion of additional requirements as they are identified. Information
compiled must include, at a minimum, the full citation for the requirement identified, where the full text
of the requirement can be found for review, and a brief statement addressing specific applicability to the
environmental aspects. This information will be maintained in EMPs and in EISIS Database.
3.2 Identification of New and Emerging Requirements

4-44
The EPMs must review the identified legal and other requirements on a regular basis, but at least
annually. When legal and other requirements change, the EPMs must notify the EMS Manager.
Sources of applicable requirements information that may be relevant in this analysis include:
 Publications dedicated to regulatory information and updates such as the Environmental
Compliance Alert and the Federal Register;
 Periodic contact with state and local regulatory officials;
 Consultation with external regulatory compliance experts that provide professional services to
the location;
 Periodic attendance at environmental training courses that include regulatory updates and
compliance issues;
 Identifying local requirements through locally mandated permits; and
 Consultation with site management and headquarters staff on new or revised requirements that
may apply to site operations.
Timely notification of changes is necessary to ensure continuous compliance with legal and other
requirements these changes must also be supplied to the EMS Manager.
Updates to legal and other requirements will then be used to continually improve relevant parts of the
EMS, particularly the relevant EMPs.
3.3 Applicability to Pueblo Chemical Depot’s Environmental Aspects
Once the baseline of existing legal and other requirements has been established they will be integrated
into the EMS when determining the significance of PCD’s environmental aspects, during the
establishment of objectives and targets for the EMS, and through their inclusion in Environmental
Management Plans (EMPs) designed to achieve those objectives and targets. The identification of the
legal and other requirements will also be used to help ensure that PCD operations maintain compliance
to those requirements.
4.0 Records
The EMS Manual will contain a current list of legal and other requirements and their associated aspects.

4-45
4.8 PCD EMS Procedure for Monitoring and Measurement
This procedure outlines the process for monitoring and measuring the key characteristics of PCD
operations that may have significant impacts on the environment. Monitoring and measuring ensures
that PCD is meeting its environmental policy, objectives, and targets through the EMS.
2.0 Definitions
3.0 Procedure
Monitoring and measuring of key characteristics and environmental performance associated with
significant aspects will be specified in the Environmental Management Programs (EMPs) as Program
Indicators.
3.1 Roles and Responsibilities:
3.1.1 Environmental Program Manager (EPMs): Each EPM will verify performance in
meeting environmental objectives and targets through the monitoring and measurement of specified
program indicators. In addition, EPMs are responsible for evaluating the results of the monitoring and
measuring efforts, and track how well objectives and targets are being met. Periodically, EPMs will
tabulate monitoring and measuring data on progress for assigned objectives. Progress reports will be
distributed to management, as appropriate, to ensure oversight and accountability.
3.1.2 Management Review of Program Data: Management will review the reports and meet
with the EPM or other appropriate personnel if nonconformities are found or progress is falling
significantly behind schedule.
3.2 Utilization of EMS Performance Data – All information collected from the monitoring and
measuring of progress in attaining the objectives and targets of the EMS is a required input into the
periodic EMS Management Review by top management. The effectiveness of the EMS is in large
measure determined by its effectiveness in meeting the objectives and targets.
3.3 Establishing Indicators and Baselines
3.3.1 Selection of Program Indicators – Program Indicators are selected as part of establishing
Environmental Management Programs (EMPs) for significant aspects. They are selected for the
objectives and targets in the EMP and for any other objectives and targets specified in the EMS.
The indicators allow the organization to measure progress towards the attainment of objectives
and targets.
Other factors to consider when selecting indicators for regulatory targets are the provisions in
regulations that often specify the unit of measure that needs to be monitored and/or controlled for
the given environmental aspect. For example, air emissions may include particulates and volatile
organic compounds and can be measured by volume, concentration, and periodicity; recyclables

4-46
can be measured by weight, volume, or value; hazardous waste can be measured by toxicity,
corrosiveness, flammability, combustibility, weight, etc.
Examples of indicators for the EMS system itself may include: The percentage of employees that
have not received awareness training; the time lapse from finding a nonconformance to
implementing corrective action; the number of employees that have received competency
training relative to their responsibilities with respect to significant aspects.
3.3.2 Establishing Baselines – Having selected the program indicators, a typical first step is to
establish performance baselines in order to measure progress from a specific starting point.
Baselines may not be appropriate for some objectives and targets where, due to the nature of the
Input, measurement over time may not be indicative of meaningful progress.
3.3.3 Measuring Indicators – Each identified indicator must also include the methods to be
employed to monitor and measure that indicator so as to track progress. For example, if
temperature is the indicator, the technological measurement method could be a thermometer, and
the procedural methods would be the frequency of measurements or location of measurements.
It is also important to specify the records that will be created with this information and where
and for how long such records will be kept.
4.0 Records
This procedure will generate the following records:
 Records of baselines for objectives and targets of the EMS;
 Data records of ongoing or periodic measurement and monitoring, as appropriate;
 List of instruments used for monitoring and measurement of EMS program indicators that
require periodic calibration;
 Records of calibration instructions; and
 Records of actual calibrations (when and by whom)
Refer to PCD’s EMS Procedure for Documentation and Records Management for further details on
document retention.

4-47
4.9 PCD EMS Procedure for EMS Management Review
This procedure is implemented at PCD as a guideline for the periodic management reviews of the
installation’s Environmental Management System (EMS). Implementation of this EMS procedure will
ensure the periodic review of the EMS for its continued suitability, adequacy, and effectiveness.
Additionally periodic management reviews will address the need for modifications to policy, objectives
and targets, and other elements of the EMS.
2.0 Definitions
3.0 Procedure
The management review of PCD’s EMS will be conducted on an annual basis, as part of the EQCCl,
unless circumstances warrant a more frequent review. The review will cover key elements of the EMS
and will include necessary and sufficient information for management to make informed decisions on
whether the EMS continues to be suitable, adequate and effective for its intended purposes, and for
taking decisions or authorizing actions that need to be taken by PCD personnel to ensure the continual
improvement of one or more of its elements.
3.1 Participant Roles and Responsibilities
PCD’s Depot Commander, or in his absence a designee, will serve as the Chairperson for the
Management Review.
EMS Manager is responsible for coordinating and scheduling meetings with appropriate
personnel to review PCD’s EMS.
Third Parties: Any interested third parties not directly involved in the EMS review (e.g.,
PCAPP) may be invited by the Director of EMO if their presence is relevant.
3.2 Contents of the Management Review:
At a minimum, the following items will be discussed during the EMS management review:
 Results from recently completed EMS audits;
 Communication from external interested parties to include complaints received;
 Status report on the progress of attaining objectives and targets (refer to the EMS Procedure for
Objectives and Targets);
 Status of regulatory compliance;
 Status of corrective and preventive actions to include information on violations received since
the last EMS review;
 Status of action items from previous EMS management reviews;
 Developments in legal and other regulatory requirements (refer to the EMS Procedure for Legal
and Other Requirements) related to PCD’s environmental aspects (refer to the EMS Procedure
for Identifying Significant Environmental Aspects); and

4-48
 Recommendations for improvement of the EMS.
In addition, the EMS management review will evaluate the need to change the environmental policy,
objectives and targets, and other elements of the EMS due to the following:
 Changes in mission;
 Addition of new facilities;
 Changes in expectations and requirements of interested parties;
 Changes in the Inputs of the installation;
 Advances in science or technology;
 Lessons learned from environmental incidents or emergency response; and
 Changes in reporting and communication structures within the installation.
3.3 Results of the Management Review
Results of the management review will include:
 The identification of areas of opportunity for continual improvement of the EMS that lead to
improved environmental performance;
 The identification of the root cause(s) of nonconformance or deficiencies;
 Management approval for new corrective and preventative action plans or concurrence that
existing plans continue to be adequate and effective;
 Identification of procedural changes resulting from process improvement; and
 The identification of needed changes to the environmental policy, objectives and targets or other
elements of the EMS.
4.0 Records
Records generated by this procedure will be maintained by EMO include:
 Minutes or notes of the management review that cover the attendance, the information that was
presented, the determinations made, and the decisions taken; and
 Records of follow-up actions initiated and completed to give effect to top management decisions
taken in the review.

4-49
4.10 PCD EMS Procedure for Nonconformity, Corrective and Preventive action
The purpose of this procedure is to describe the process to identify actual and potential nonconformities
and specify a process to make corrective and preventive actions. Implementation of this EMS procedure
will ensure that nonconformities are addressed in a timely manner, corrective and/or preventive actions
are taken, and investigations are conducted to determine their cause so as to avoid their recurrence.
2.0 Definitions
3.0 Procedure
3.1 General: Potential or actual nonconformities can be identified from audits and other reviews; from
findings, conclusions, and recommendations reached as a result of measuring and monitoring; from
accidents or spills; from employee observations or comments; and from changes to Pueblo Chemical
Depot mission, Inputs, or structure. Typical causes of nonconformities include poor communication,
faulty or missing procedures, equipment malfunctions, lack of training, lack of understanding of
requirements or procedures, failure to enforce rules or procedures, and corrective actions that fail to
address root causes of problems.
3.2 Responsibilities: The EMO Director has the overall oversight responsibility to ensure
nonconformities of the EMS are corrected and actions are taken to avoid their recurrence.
3.3 Correcting and/or Preventing Actions:
3.3.1 Whenever a nonconformance in the EMS is detected it will be reported to the EMS Manager
for documentation and follow-up.
3.3.2 The EMS Manager assigns the Nonconformity to the appropriate Environmental Program
Manager for investigation and resolution.
3.3.3 The Environmental Program Manager confers with the affected operational management to
investigate the root cause, develop appropriate corrective and preventive actions, and oversee
implementation of those actions, as appropriate.
3.3.4 The EMS Manager approves or rejects the completion of the corrective and preventive
actions of internal reported nonconformances. Nonconformances identified by external
parties will be approved or rejected by the EMO Director.
4.0 Records
Records generated by this procedure include the following and are maintained by EMO:
 Records that list the instances of nonconformances of the EMS, the date of occurrence, date
of corrective action, and date of completion of preventive action;
 Records that reflect the analysis of the nonconformance, and the corrective and preventive
actions that were taken with respect to it; and

4-50
 Records of changes made to any of the EMS procedure(s) as a result of implementing
corrective and preventive actions.

4-51
4.11 PCD E MS Procedure for Setting Objectives and Targets
The purpose of this procedure is to outline how PCD provides a consistent means for developing EMS
objectives, targets and program indicators. Objectives and targets will be established to address the
significant environmental aspects identified at PCD and must adequately address compliance with the
legal and other requirements.
The objectives and targets established with this EMS procedure extend to all levels and functions of the
organization(s) where they are applicable.
A list of Objectives is provided as Appendix A.
2.0 Definitions
3.0 Procedure
The EMO Environmental Program Managers will propose objectives and targets for the significant
environmental aspects identified at PCD. They will also establish the program indicators necessary to
measure achievements associated with the objectives and targets. Once the objectives, targets and
program indicators are set, they will be reviewed by EMS Manager and the EMO Director.
Environmental Program Managers will develop objectives and targets to define:
 The performance objectives (e.g., monitor, study, control or improve) for the significant
environmental aspects;
 The specific, quantified targets which particularize those performance objectives; and
 The planned schedule for achieving targets.
Whenever possible, objectives will be set in measurable terms with specific time frames for their
accomplishment to facilitate performance monitoring and trends analysis. Objectives for significant
environmental aspects should be set irrespective of their suitability for measurement. In most cases, it is
appropriate to establish a baseline against which to measure progress and as such the first cycle of
measurements will act as a baseline against which to quantify future performance.
Objectives and targets will be integrated into Environmental Management Programs (EMPs) that are
developed and implemented to stimulate action within individual units, departments or across all
operations within the scope of the EMS. Development of objectives and targets take into account:
 Pueblo Chemical Depot Environmental Policy;
 Identified significant aspects;
 Legal and other requirements;
 Views of interested parties;
 Mission requirements
 PCD’s sustainability goals;
 Pollution prevention goals;
 Achievement of continual improvement of the EMS;
 Technological options;

4-52
 Financial, operational, and organizational requirements; and
 The Installation Master Plan
Objectives and targets will be included in the EMP documentation, and are also summarized in a listing
that is compiled and maintained by the installation’s EMS Manager, or his designee.
PCD will establish program indicators (measures) when setting objectives and targets, and will include
these within the EMP documentation. Program indicators will be set for all targets and for objectives
when that is appropriate. These may include indicators for environmental performance, compliance,
pollution prevention, and/or other elements of the EMS for which objectives and targets have been
established. Program indicators will be tracked as part of the EMPs to ensure that objectives and targets
are on track for attainment within their specified timeframes.
When setting objectives and targets, Program Managers shall obtain estimates for the additional
resources needed for their achievement. Management shall apply financial, operational, and
organizational considerations when approving the recommended objectives and targets.
4.0 Records
Records that pertain to the setting of objectives and targets for the installation’s EMS will be maintained
electronically and will be readily available to Depot management. Records will include, but will not be
limited to:
1. The final approved list of objectives for the installation’s EMS ( in EMS Manual);
2. The documented views of interested parties, if applicable;
3. Accomplishment of objectives and targets (in EISIS Database); and
4. Information on additional resources needed to achieve the objectives and targets.
Refer to PCD’s EMS Procedure for Documentation and Records Management for further details on
document retention.

4-53
Attachment A
Objective List
1. To maintain compliance with all applicable legal, regulatory and other requirements.
2. Maintain a self sustaining forestry, wildlife, and land management program (income and
sustainable management practices) in accordance with INRMP.
3. Provide assistance and support to the P2 program to evaluate P2 opportunities and to implement those
that have been approved for implementation.
4. To create operational controls for identified Inputs that are to be included in SOP.
5. To improve the flow of information in relation to facility maintenance activities or any other activities
where asbestos may be encountered.
6. To evaluate energy saving opportunities to reach a goal of 30% reduction by 2015.
7. To evaluate water conservation opportunities to reach a goal of 16% reduction by 2015.
8. Continue to encourage community outreach programs.
9. Control Public health pests, structural damage from pests, and undesirable vegetation.

4-54
4.12 PCD EMS Procedure for the Control of Records
The purpose of this procedure is to describe the process for managing records that document Pueblo
Chemical Depot’s EMS operations and performance.
2.0 Definition
3.0 Procedure
3.1 General: Records demonstrate the ongoing operation of Pueblo Chemical Depot’s EMS and its
conformance to arrangements specified in the EMS. Records also allow Pueblo Chemical Depot to track
its progress in meeting its objectives, targets and overall management performance. Environmental
records must:
 be legible, identifiable and traceable to the Input, product or service involved
 be stored and maintained so that they are readily retrievable and protected against damage,
deterioration or loss
 have established and recorded retention times
3.2 Responsibilities:
Environmental Management Office Director – The PCD EMO Director will:
a. Appoint in writing a Record Control Officer.
b. Approve all record retention times.
Environmental Program Managers - Pueblo Chemical Depot’s Environmental Program Managers
have the overall responsibility for the identification, storage, protection, retrieval, retention, and disposal
of Pueblo Chemical Depot’s EMS records related to their programs.
Records Control Officer – The Records Control Officer will ensure that EMS and Quality records are
being maintained in accordance with appropriate procedures.
3.3 Record Identification and Storage: Each program manager will identify records that are required
for their programs. The EMS Manager will maintain records that result from EMS Procedures that are
not covered under any of the EMPs. Other EMS records not related to EMPs will be maintained by the
EMS Manager or his designee.
3.4 Record Retrieval: Requests for program specific records should be routed through the appropriate
Environmental Program Manager. Other EMS records that are maintained on the Pueblo Chemical
Depot intranet web site may be reviewed and retrieved by any Pueblo Chemical Depot personnel with
access to the system.
3.5 Record Review: Environmental Program Managers will review records and discard those no
longer needed in accordance with the records retention and disposal section of the procedure. Records
maintained on the EMS web site will be reviewed on an annual basis to determine if they are still
appropriate to retain.
3.6 Record Retention and Disposal: A record is a permanent document that typically will not be
revised. However, new records are normally generated for EMS operations and activities (e.g., new

4-55
audit reports). Pueblo Chemical Depot’s EMS Manager or Environmental Program Managers will
decide which records to retain or archive, and which records can be disposed. In many cases the
duration a record should be retained may be governed by a regulatory or legal requirement. Where
necessary or prudent, Environmental Program Managers should coordinate with PCD’s Legal Office to
ascertain safe retention periods.

4-56
4.13 PCD EMS Procedure for Competency Training
The purpose of this procedure is to provide guidelines for the conduct of periodic environmental
awareness and competence training (as required) of all personnel at Pueblo Chemical Depot (PCD).
Such training is the foundation for personnel awareness, involvement, and commitment to
environmental protection as an ongoing responsibility of work life. It is fundamental to the efficient and
effective implementation and execution of the PCD EMS.
To further the EMS, PCD will periodically conduct both General Environmental Awareness and
Competence Training:
1. All PCD personnel, whether or not they are associated with significant environmental aspects,
shall receive General Environmental Awareness Training.
2. Competence Training is provided, as necessary, to ensure proficiency of personnel whose work
may create or contribute to a significant environmental impact.
2.0 Definitions
3.0 Approach
3.1 General Environmental Awareness Training – The objectives of general environmental
awareness training is to make all appropriate PCD personnel aware of:
a. The importance of conformance with the PCD Environmental Policy and procedures, and
with the requirements of the EMS;
b. Their roles and responsibilities in achieving conformance with the Environmental Policy
and procedures and with the requirements of the EMS; and
c. The potential consequences of departure from specified operating procedures;
d. Their responsibility to report spills or other releases; and
e. Their responsibility to report nonconformities or suggested improvements to the EMS.
General Environmental Awareness Training will be conducted for all personnel as part of the initiation
of the EMS. New employees will receive awareness training as part of the new employee orientation
training. Periodically, all employees will receive refresher awareness training that reemphasizes the
above stated elements. General Environmental Awareness Training will be provided during the course
of EMS development and implementation at appropriate times to the groups represented in attachment A
below.
3.2 Competence Training – PCD will identify significant environmental aspects according to
PCD’s EMS Procedure for Identifying Significant Environmental Aspects and Impacts. Following this,
the Inputs that have the potential to cause a significant environmental impact will be identified and
documented accordingly.
The Environmental SOP’s will be provided to the appropriate areas. Division Directors will be
responsible for understanding and training their personnel on their responsibilities.

4-57
Personnel that perform tasks that can cause significant environmental impacts shall be competent on the
basis of appropriate education, training, and/or experience. Such personnel shall receive competence
training when it is determined that it is required to address the significant environmental aspect(s) that
are associated with their work assignments. Such Competence Training will include:
a. Environmental training required by applicable regulatory requirements
b. The significant environmental impacts, actual or potential, of their work activities and the
environmental benefits of improved personal performance;
c. Their roles and responsibilities in achieving conformance with the Environmental Policy
and procedures, and with the requirements of the EMS, including emergency
preparedness and response requirements. Specific objectives and targets related to their
work activities
d. The potential consequences of departure from specified operating procedures;
Declaration of competence for personnel named in the Environmental Management Programs (EMPs)
shall be documented in each EMP. Where competence training is indicated as the reason for such
declaration, a reference to that training should be provided. Supervisors will maintain training records
to provide evidentiary proof of such training. (Note: In many cases, Competence Training will be
satisfied by existing Health and Safety training required by OSHA and/or environmental regulations.)
When competence training is required, it will be conducted before the individual begins an assigned
function that has the potential to have a serious environmental impact. Such Competence Training could
include formal training or on the job training. It is the responsibility of the immediate supervisor to
ensure that the individual has appropriate competence.
Contractors whose work may cause a significant environmental impact and that work at PCD for more
than six months will be identified and required competency training for those individuals that need such
training.
4.0 Records
Records that pertain to competency training for the installation’s EMS will be maintained either in hard
copy or electronically and will be readily available to management. Records will include, but will not
be limited to:
1. Awareness training documentation (mechanisms used for training dissemination);
2. The contents of the awareness training;
3. Competence training records (date and attendance); and
4. The contents of competence training.

4-58
Attachment A
Required Training for Appropriate PCD Groups
Group Required Training
EMS Program Manager EMS Orientation Training
EMS Lead Auditor Training
Organizational Leadership Training
Director Environmental Management
Office
EMS Orientation Training
Environmental Program
Managers
EMS Orientation Training
EMS General Environmental Awareness Training
EMS Internal Auditors EMS Auditor Training (at least one Lead)
Top Management EMS Orientation training
All Employees EMS General Environmental Awareness
Competence Training, if appropriate
Long Term Contractors (> 6 months or $
amount of contract)
Same as "all employees"
Tenants (covered by the scope) Same as "all employees"
Short Term Contractors (< 6 months) Competence Training, if appropriate

5-1
5. EMS Records
1. Introduction
This chapter references the records of actions completed under the EMS, including carrying out the
procedures. For example, these should include records of having identified significant aspects, delivered
training, and conducted EMS audits.
2. Records/References
a. Records of the process of identifying significant aspects are located in the PCD Input/Aspect
spreadsheets. These are in the office of the EMS Coordinator in the EMO.
b. The location of records that are a result of the execution of specific operational controls is
described in each operational control document (see Chapter 5).
c. Records related to EMS awareness training attendance within each PCD organization are
maintained by that organization.
d. Records pertaining to EMS internal and external audits are located in the office of the EMS
Coordinator.

UNCLASIFIED
PUEBLO CHEMICAL DEPOT
LEAD MANAGEMENT PLAN
Prepared by
Pueblo Chemical Depot Environmental Management Office
December 2011
Prepared by: Keith L. Phillips

UNCLASIFIED
Page1
TABLE OF CONTENTS
Section Page
TABLE OF CONTENTS ............................................................................................................................................1
DEFINITIONS 2
CHAPTER 4 12
WORK PERMIT SYSTEM......................................................................................................................................12
5.2 CERTIFICATION TRAINING ..........................................................................................................................13
SAFE WORK PRACTICES.....................................................................................................................................14
CHAPTER 7 15
WASTE DISPOSAL..................................................................................................................................................15
8.2 MEDICAL RECORDS ....................................................................................................................................16
8.4 OPERATION AND MAINTENANCE RECORDS.................................................................................................16
8.5 OTHER FORMS ............................................................................................................................................17
[Type text]

UNCLASIFIED
Page2
DEFINITIONS
Abatement – A comprehensive process of permanently eliminating exposure or potential
exposure to lead-based paint and lead dust through removal, replacement, encapsulation or
enclosure.
Action Level - Employee exposure, without regard to the use of respirators, to an airborne
concentration of lead of 30 micrograms per cubic meter of air (30 ug/m3
) calculated as an 8-hour
time-weighted average (TWA).
Encapsulation – Coating or sealing the lead-based paint with a durable coating that is applied as
a liquid to the painted surface to prevent or control chalking or flaking.
Enclosure – Enclosing the painted surface with a durable substance such as drywall, paneling,
metal, siding, plaster, or some other construction material to permanently seal the existing
surface.
Hazardous Waste - For waste in lead abatement jobs, hazardous waste is any waste that
contains more than 5 parts per million (ppm) leachable lead as determined by the Toxicity
Characteristic Leaching Procedure TCLP test, or waste that is corrosive, ignitable or reactive and
is not otherwise excluded from regulation
Lead – Includes metallic lead and all inorganic and organic compounds
Lead-Based Paint – 1). Paint already applied (in situ). Paint or other surface coatings that
contain lead in excess of 1.0 milligram per square centimeter (mg/cm2
) when using the X-ray
Fluorescence Analyzer or 0.5% by weight (or 5,000 ppm) when using Atomic Absorption
Spectroscopic analysis. 2). Paint in liquid form. Paint that contains more than 0.06% (600
ppm) lead by weight in the total non-volatile content of the liquid paint. (Consumer Product
Safety Commission).
Lead Hazard – Any condition that causes exposure to lead that would result in adverse human
health effects and that comes from a) lead-contaminated dust b) bare, lead-contaminated soil or
c) lead-contaminated paint that is deteriorated or present on accessible, friction or impact
surfaces that would result in adverse human health effects.
Lead-Contaminated Dust – Surface dust in residential dwellings that contains an area or mass
concentration of lead in excess of a) Floor: >100 micrograms per square foot (ug/ft2
), b) Window
Sill: >500 ug/ft2
, or c) Window Well: >800 ug/ft2
Removal – Separating the paint from the substrate and disposing of the removed paint.
Replacement – Removing both the paint and the substrate and disposing of both. The removed
components are then replaced to complete the abatement.
Response Action – Any action taken to abate lead-based paint that has been damaged and
presents a risk to occupants. Accomplishment of this action must be by EPA-certified abatement
workers.

UNCLASIFIED
Page3
ACRONYMS/ABBREVIATIONS
CDPHE Colorado Department of Public Health and Environment
CFR Code of Federal Regulations
CMA Chemical Materials Agency
CMA Competent Medical Authority
DA Department of the Army
D&D Demolition and Decontamination
DOT Department of Transportation
DPW Directorate of Public Works
DTC Document Tracking Center
EMO Environmental Management Office
EPA Environmental Protection Agency
FIR Facility Inspection Report
IH Industrial Hygienist
LBP Lead-Based Paint
LMP Lead Management Program
LPM Lead Program Manager
mg/cm2
milligrams per square centimeter
mg/L milligrams per liter
NEPA National Environmental Protection Act
NIOSH National Institute of Occupational Safety and Health
OSHA Occupational Safety and Health Administration
PAO Public Affairs Office
PCD Pueblo Chemical Depot
PEL Permissible Exposure Limit
PPE Personal Protective Equipment
ppm parts per million
RCRA Resource Conservation and Recovery Act
REC Record of Environmental Consideration
TCLP Toxicity Characteristic Leaching Procedure
TWA Time-weighted Average

UNCLASIFIED
Page4
ug/ft2
micrograms per square foot
ug/m3
micrograms per cubic meter
USACE U.S. Army Corps of Engineers

UNCLASIFIED
Page5
CHAPTER 1
INTRODUCTION
Lead is a common element that was used in the past as an additive to paint. It has also been used
for the production of munitions and pipe conduits, as well as for many other applications.
Approximately three-quarters of buildings, facilities, and housing constructed prior to 1978
contain some lead-based paint (LBP). Today the use of lead is limited due to associated health
and environmental problems. At Pueblo Chemical Depot (PCD), lead is primarily found in
interior and exterior paint applied to buildings and structures. In addition, lead is found at gun
and artillery ranges where lead munitions were used.
Lead-based paint, if properly managed and maintained, poses little risk. If allowed to
deteriorate, lead from paint can be a health hazard. LBP presents a hazard when it becomes
airborne and/or finely divided. Inhalation is the primary exposure route for lead. Inhalation of
dust and fumes and ingestion due to hand-to-mouth contact with lead-contaminated food,
cigarettes, clothing, or other objects are the main routes of worker exposure to lead. Another
concern is soil that surrounds homes and other buildings due to contamination from LBP that has
chipped off over many years.
1.1 Goals
The Lead Management Program (LMP) is designed to protect the health and safety of all persons
who may come into contact with on-site lead and to comply with regulations set forth by the U.S.
Army, U.S. Environmental Protection Agency (EPA), the Occupational Safety and Health
Administration (OSHA), and all appropriate state and local regulatory agencies.
The overall goals of the LMP are as follows:
• Identify lead hazards including LBP, firing ranges, and other lead contamination.
• Ensure the proper control and cleanup of any previously released lead contamination.
• Maintain existing LBP that is in good condition.
• Prevent exposure of personnel and the environment to harmful levels of lead from paint
and other sources.
• Ensure compliance with applicable policies, rules, regulations and laws.
• Ensure that potentially exposed personnel are adequately trained.
This LMP does not address in detail lead contamination in drinking water; such contamination is
regulated under federal EPA guideline 40 Code of Federal Regulations (CFR) Part 141. The
LMP will be updated as needed in order to incorporate changes in local, state, and Federal
regulations, policies, and procedures.

UNCLASIFIED
Page6
1.2 Regulatory Drivers
Key regulations and Army policies that are pertinent to the Lead Management Program are
summarized below:
1.2.1 Occupational Safety and Health Administration (OSHA)
• 29 CFR 1910.134. Respiratory Protection
• 29 CFR 1910.1025. Lead (General Industry Standard for Lead)
Identifies a Permissible Exposure Limit (PEL) of 50 micrograms of lead per cubic meter of air
(ug/m3
) averaged over an 8 hour period and an action level of 30 ug/m3
, time weighted average
(TWA), based on an 8 hour work-day.
• 29 CFR 1910.1200. Hazard Communication.
• 29 CFR 1926.20. General Safety and Health Provisions.
• 29 CFR 1926.62. Lead (Construction Industry Standard for Lead).
Establishes the same exposure limits as the General Industry Standard.
1.2.2 Environmental Protection Agency (EPA)
• 40 CFR 261. Identification and Listing of Hazardous Waste
• 40 CFR 262. Standards Applicable to Generators of Hazardous Waste
• 40 CFR 263. Standards Applicable to Transporters of Hazardous Waste
• 40 CFR 745. Lead-Based Paint Poisoning Prevention in Certain Residential Structures
1.2.3 Department of Transportation Regulations (DOT)
• 49 CFR 171-173. Transportation Requirements, Packaging, Labeling, Marking and
Placarding
1.2.4 United States Department of the Army
• Army Regulation 200-1. Environmental Protection and Enhancement
• Army Public Works Technical Bulletin 420-70-2. Installation Lead Hazard Management
1.2.5 State of Colorado
• Colorado Department of Public Health and Environment, Regulation No. 19, Lead-Based
Paint Abatement

UNCLASIFIED
Page7
CHAPTER 2
LEAD MANAGEMENT TEAM
The Lead Program Manager (LPM) oversees the LMP. Additional subject-matter experts who
can provide assistance as necessary include the Safety Office, the CMA Legal Representative,
the Training Office, the Directorate of Public Works (DPW), and the Public Affairs Office
(PAO). The LPM will brief the Installation Commander on an as-needed basis.
2.1 Installation Commander
The Installation Commander is responsible for the overall management of the Program. The
Installation Commander will:
• Establish a LMP in support of the Department of the Army (DA), Chemical Materials
Agency (CMA), EPA, Colorado Department of Public Health and Environment
(CDPHE) and PCD lead management policies.
• Designate an LPM.
2.2 Lead Program Manager
The LPM will perform the following activities:
• Ensure that the Lead Management Plan is available, by request, for inspection by
employees, regulatory agencies, contractors and off-site neighbors.
• Ensure that all lead abatement activities comply with applicable EPA, OSHA, state, and
local laws and regulations.
• Ensure that required notifications are submitted to the pertinent local, state, and Federal
regulatory agencies.
• Maintain records pertaining to lead for 30 years after the removal of the last lead material
or until facilities are permanently transferred to private use.
• Visit work sites when repair, maintenance, or lead removal operations are taking place in
order to verify LMP requirements.
2.3 Environmental Management Office (EMO)
EMO will perform the following activities:
• Ensure that the LMP is developed and maintained in compliance with Federal, state and
local regulations.
• Execute the LMP in accordance with Installation Commander’s guidance.
• Program and budget for adequate resources to execute effective management programs.
• Update the LMP as necessary.
• Inform facility occupants of building inspections, response actions and post-response
activities.

UNCLASIFIED
Page8
• Provide technical oversight for contracted projects involving lead operations,
maintenance and abatement.
• Ensure that lead-related activities and waste disposal are carried out in accordance with
the provisions of all applicable state, local, and federal regulations.
• Coordinate abatement activities with subject matter experts as appropriate.
2.4 Risk Management Directorate (Safety Office)
The Safety Office will:
• Assist in all safety matters related to lead management.
• Provide expertise in complying with lead safety-related Federal, state, and local
requirements.
• Provide technical assistance on lead materials management and abatement projects.
• Receive and investigate employee/occupant complaints of unsafe working or living
conditions.
• Coordinate abatement activities with subject matter experts as appropriate.
2.5 CMA Legal Representative
The CMA Legal Representative will provide legal assistance on any liability or regulatory
compliance issues related to lead or lead abatement projects.
2.6 Operations Division (Training Office)
The Training Office will:
• Provide worker education/training for individuals identified as lead workers
• Program and budget adequate resources to accomplish lead training.
2.7 Directorate of Public Works (DPW)
• Determine whether lead material may be disturbed before beginning any maintenance,
repair, or construction work.
• Budget for lead abatement contractor support services.
• Inform the Industrial Hygienist of any operations or situations that could expose depot
employees, residents, or workers to lead concentrations above the action level.
• Ensure that all lead abatement activities comply with applicable EPA, OSHA, state, and
local laws and regulations.
• Ensure that required notifications are submitted to the pertinent local, state, and Federal
regulatory agencies.
• Budget for training, equipment, and personnel needed for those removal actions
accomplished with government personnel.
• Maintain real estate records pertaining to rentals and leases in federal housing.

UNCLASIFIED
Page9
• Ensure that lead abatement contractors receive a copy of the Lead Management Plan and
that they are briefed by the Safety Office, Industrial Hygiene and EMO.
• Coordinate lead abatement or investigations with the LPM and subject matter experts as
appropriate.
2.8 Lead Abatement Contractor
• Inspect proposed construction/maintenance project areas to analyze lead hazards and to
ascertain the potential for disturbing LBP.
• Ensure projects are accomplished in a safe, efficient manner that complies with
regulatory standards and protects workers and building occupants.
• Implement a contractor sponsored respiratory protection program.
• Inspect, on a daily basis, the work site and construction area.
• Ensure that employees use hygiene facilities, practice safe work practices and follow all
required documentation procedures.
• Ensure that engineering controls are functioning properly.
• Supervise all required contractor employee exposure monitoring.
• Ensure that access to the project area by unauthorized personnel is controlled, warning
signs are in place, and containment barriers are installed and functioning properly.
• Ensure all notifications are made in accordance with appropriate regulatory and plan
requirements, and air-monitoring support is available prior to project initiation.
• Oversee the management of all bulk and air samples, provide all sample containers, and
ensure all samples are analyzed by an approved laboratory.
• Ensure that personnel are properly identified, trained, equipped, and medically certified.
• Implement a medical surveillance program.
• Coordinate lead abatement or investigations with the LPM.
2.9 Public Affairs Office
The Public Affairs Office will:
• Provide information to employees, residents (through the PCD Housing Coordinator),
and contractors regarding on-going and planned lead abatement projects
• Provide information to the media, if necessary or appropriate.
2.10 PCD Housing Coordinator
The PCD Housing Coordinator will ensure that residents receive information regarding LBP or
abatement projects as required in 24 CFR Part 35 and 40 CFR Part 745.

UNCLASIFIED
Page10
2.11 Preventive Medicine
The Industrial Hygienist (IH) and Competent Medical Authority (CMA) responsibilities are:
• To advise on selection of personal protective equipment for abatement projects and to
provide technical assistance.
• To provide medical surveillance and maintain records, as outlined by OSHA and the
National Institute of Occupational Safety and Health (NIOSH), to eligible federal or DA
civilian employees subject to occupational lead exposure.
• To review sampling results that document exposure or potential exposure to Depot
employees.

UNCLASIFIED
Page11
CHAPTER 3
NOTIFICATION AND LABELING
The final rule, “Lead; Requirements for Disclosure of Known Lead-Based Paint and/or
Lead-Based Paint Hazards in Housing,” (61 FR 9604-9088) requires that persons leasing
federally-owned residential housing built prior to 1978 receive a lead hazard information
pamphlet. Housing residents must be notified of known LBP and/or lead hazards in accordance
with 24 CFR Part 35, 40 CFR Part 745 and AR 420-70.
PCD, when renting or leasing property, must take the following actions:
• Disclose all known lead-based paint hazards, lead material hazards and any available
reports on lead to the housing occupants.
• Give renters the EPA pamphlet “Protect Your Family From Lead in Your Home.”
• Include certain warning language in the lease and get signed statements from all parties
verifying that all requirements were completed.
• Retain signed acknowledgement for 3 years, as proof of compliance.
PCD will post warning signs in each work area where the PEL is exceeded in accordance with 29
CFR 1910.1025 (m)(2)(i).

UNCLASIFIED
Page12
CHAPTER 4
WORK PERMIT SYSTEM
Project planning at PCD will take lead materials management into account. As part of the
planning process for Demolition and Decontamination (D&D) projects, PCD will complete a
Facility Inspection Report (FIR) to document environmental issues, including lead materials
locations. The FIR will be used to plan for lead mitigation.
The Environmental Checklist for Work Orders and Contract Proposals is used to identify
projects or actions that require additional environmental analysis or documentation. The
checklist identifies lead issues. An environmental impact analysis for lead hazard control and
LBP activities will be prepared in order to satisfy the requirements of the National
Environmental Protection Act (NEPA). This analysis will be prepared by the proponent and
approved by EMO in the form of a Record of Environmental Consideration (REC) or other
appropriate NEPA document.
If disturbance of lead is intended or likely, a lead abatement plan will be developed by personnel
with EPA-certified lead training. A licensed and qualified contractor will be engaged to perform
the abatement. DPW will write the statements of work and contracts for all lead abatement
projects.
Contractors are responsible for making appropriate state and Federal notifications for any
lead-related demolition, renovation, or abatement work. If work is done by PCD personnel,
DPW will make the appropriate notifications before work is started.

UNCLASIFIED
Page13
CHAPTER 5
EDUCATION AND TRAINING
Contractors are responsible for providing properly trained workers for PCD projects.
Certificates, as proof of training, are required for project records.
5.1 Awareness Training
Workers who may be exposed to lead at or above the lead action level, or for whom the
possibility of skin or eye irritation exists, are required to complete OSHA Lead Awareness
Training. This class consists of an initial 1-hour training program and an annual refresher (29
CFR 1926.62 and 29 CFR 1910.1025). The training program should include the following:
• The physical characteristics of lead.
• Methods of identifying known and suspect LBP in buildings and an overview of known
locations of known and suspect LBP.
• Health effects associated with lead exposure.
• Overview of the LMP.
• Types of operations that would result in exposure to lead and methods of minimizing
exposure including engineering controls, work practices, and personal protective equipment
(PPE).
• The purpose, proper selection, fitting, use and limitations of respirators.
• The purpose and description of the medical surveillance program and the medical removal
protection program.
5.2 Certification Training
Lead workers may participate in advanced training commensurate with assigned responsibilities.
The following courses, presented by CDPHE- accredited training providers,
• Lead Inspector
• Lead Risk Assessor
• Lead Project Designer
• Supervisor of Lead Abatement Projects
• Lead Abatement Worker
Annual refresher courses are required to maintain certification for all levels of training.

UNCLASIFIED
Page14
CHAPTER 6
SAFE WORK PRACTICES
Mechanical disturbance of lead should be avoided. Activities such as cutting, drilling, grinding,
sanding, or hammering may cause significant damage that could lead to airborne releases.
Application of excessive heat to lead-containing materials can also be a major source of lead
exposure. If removal is necessary, a consultant should be contacted to develop a lead abatement
plan in conjunction with the Lead Program Manager. A licensed and qualified contractor will
perform the abatement.
Do not kneel on contaminated ground, stir up unnecessary dust, or perform any practice that
increases the probability of hand-to-mouth transfer of contaminated materials. Eating, drinking,
chewing gum, smoking, or using smokeless tobacco is forbidden while collecting samples or
working with lead.
The PCD Respiratory Protection Program (PCD-R 40-20) covers all types of respiratory
protection, including lead, if needed.
All contract employees who are engaged in lead abatement and related activities will be
governed by their company policies and procedures regarding respirator usage. PCD is not
responsible for activities such as fit testing, inspection, and maintenance of contract employees’
respirators.
Before any lead-related activities take place by contract employees at PCD, the contractor will
provide a copy of their respirator program and all pertinent information to the PCD Safety Office
for review.

UNCLASIFIED
Page15
CHAPTER 7
WASTE DISPOSAL
The volume of lead waste will be minimized. Lead waste is considered a hazardous waste under
the Resource Conservation and Recovery Act (RCRA) when it contains a lead content greater
than 5 milligrams per liter (mg/L)as measured by the Toxicity Characteristic Leaching Procedure
(TCLP) (40 CFR Part 261.24).
All hazardous lead waste will be handled, stored, transported, and disposed in a manner that
complies with 40 CFR Parts 260-265 and 268. The abatement contractor will be responsible for
transporting waste off-site. Storage, transportation, and disposal of hazardous lead waste will be
coordinated with the EMO. All DOT requirements for hazardous materials will be followed (49
CFR 172, 173, 178 and 179).

UNCLASIFIED
Page16
CHAPTER 8
RECORD KEEPING
The LPM and the DPW will maintain copies of all forms and documentation involving lead
through the Document Tracking Center (DTC). The following documents are part of the LMP
and will be retained at Pueblo Chemical Depot.
8.1 Shipping Manifests
A receipted copy of the “Waste Origin-Waste Disposal” form for the shipment of hazardous lead
waste will be maintained, along with other disposal paperwork, by EMO for a period of 2 years.
EMO will furnish upon request, and make available for inspection, all records required under 40
CFR 61.150.
8.2 Medical Records
Medical exam records will be kept on file for eligible federal or DA civilian employees who are
either engaged in lead work or who may have been exposed to lead in excess of the PEL for lead
of 50 (50 ug/m3
) averaged over an 8-hour work-day. The Competent Medical Authority (CMA)
must keep all records of exposure monitoring for airborne lead. These records must include the
name and job classification of employees measured, details of the sampling and analytic
techniques, the results of this sampling, and the type of respiratory protection being worn by the
person sampled. Competent Medical Authority CMA is also required to keep all records of
biological monitoring and medical examination results. These must include the names of the
employees, the physician's written opinion, and a copy of the results of the examination. All of
the above kinds of records must be kept for 40 years, or for at least 20 years after termination of
employment, whichever is longer (29 CFR 1910.1025 and 29 CFR 1926.62).
8.3 Training Records
For each person requiring training, the Training Office will keep on file the person’s name, job
title, date training was completed, type of training, location of the training, and number of hours
completed. Training records must be maintained for the duration of employment plus 1 year.
8.4 Operation and Maintenance Records
D&D project files are maintained with contract documents by DPW. These files may contain
start and completion dates of the work, names and addresses of all contractors involved and their
state/EPA accreditation numbers. If lead-containing material is shipped off-site, hazardous
waste manifests will be maintained by the EMO.
Building and facility owners shall maintain records of all information concerning the presence,
location and quantity of LBP. Such records shall be kept for the duration of ownership and shall
be transferred to successive owners. All records should be recorded in the DTC.

UNCLASIFIED
Page17
8.5 Other Forms
The LPM will maintain records of lead incidents that are not related to contracted Public Works
projects. The DPW will maintain records of lead abatement done in conjunction with building,
demolition and other contract projects.
Records should be made available upon request to appropriate OSHA representatives in
accordance with applicable Federal, state, or local laws. Sampling results and medical records
should be made available to appropriate affected employees, former employees, and designated
representatives in accordance with Federal, state, or local laws.
Due to potential liability issues and concerns associated with lead, all employee records will be
kept on file for the duration of employment plus 30 years.

UNCLASIFIED
Page18
U.S. ARMY CHEMICAL MATERIALS AGENCY
LEAD MANAGEMENT PLAN
December 2011
Approval Page
Prepared by:
Keith L Phillips Date
Environmental Engineer, EMO
Reviewed by:
Date
Director, Environmental Management Office
Concurrences:
Date
Safety Officer
Date
Director, Risk Management Directorate
Date
Director, Public Works
______________________________________________________ _________________
Date
Industrial Hygienist

UNCLASIFIED
Page19
______________________________________________________ ________________
Date
Chief, Fire Department
_____________________________________________________ ________________
Date
Competent Medical Authority
APPROVED:
_____________________________________________________ _______________
Date
Commanding

UNCLASIFIED
Page0
ASBESTOS MANAGEMENT PLAN
Prepared by
Pueblo Chemical Depot Environmental Management Office
December 2011
Prepared by: Keith L. Phillips

UNCLASIFIED
Page1
DEPARTMENT OF THE ARMY
45825 HIGHWAY 96 EAST
PUEBLO CO
PCD ASBESTOS MANAGEMENT PLAN December 2011
TABLE OF CONTENTS
TABLE OF CONTENTS ............................................................................................................................................1
LIST OF TABLES.......................................................................................................................................................2
LIST OF FIGURES.....................................................................................................................................................2
APPENDIX ..................................................................................................................................................................2
CHAPTER 1 INTRODUCTION................................................................................................................................3
1.1 PURPOSE.......................................................................................................................... 3
1.2 OVERVIEW...................................................................................................................... 3
1.3 GOALS.............................................................................................................................. 3
1.4 REGULATORY DRIVERS.............................................................................................. 4
CHAPTER 2 ASBESTOS MANAGEMENT TEAM ...............................................................................................6
2.1 INSTALLATION COMMANDER....................................................................................... 6
2.2 ASBESTOS PROGRAM MANAGER ................................................................................. 6
2.3 ENVIRONMENTAL MANAGEMENT OFFICE (EMO).................................................... 7
2.4 PREVENTIVE MEDICINE .................................................................................................. 7
2.5 PUBLIC AFFAIRS OFFICE (PAO) ..................................................................................... 7
2.6 CMA1 LEGAL REPRESENTATIVE................................................................................... 8
2.7 RISK MANAGEMENT DIRECTORATE (RMD)............................................................... 8
RMCD IS RESPONSIBLE FOR THE FOLLOWING: .............................................................. 8
2.9 TRAINING OFFICE ............................................................................................................. 8
2.10 CONTRACTOR .................................................................................................................. 9
CHAPTER 3 IDENTIFICATION OF ACM...........................................................................................................12
3.1 PURPOSE............................................................................................................................ 12
3.2 RENOVATION AND NEW FACILITY CERTIFICATION............................................. 12
3.3 ABATEMENT ALTERNATIVES...................................................................................... 12
CHAPTER 4 BUILDING OCCUPANT NOTIFICATION...................................................................................13
4.1 SCOPE................................................................................................................................. 13
4.2 POSTINGS .......................................................................................................................... 13
CHAPTER 6...............................................................................................................................................................14
CHAPTER 5 WORK CONTROL SYSTEM ..........................................................................................................15
CHAPTER 6 TRAINING .........................................................................................................................................16
6.1 ASBESTOS AWARENESS TRAINING............................................................................ 16
6.2 ADVANCED ASBESTOS TRAINING.............................................................................. 16
CHAPTER 7 RESPIRATORY PROTECTION PROGRAM ...............................................................................17

UNCLASIFIED
7.1 PURPOSE............................................................................................................................ 17
7.2 PUEBLO CHEMICAL DEPOT RESPIRATOR PROGRAM............................................ 17
7.3 CONTRACTOR RESPIRATOR PROGRAM .................................................................... 17
8.1 SURVEILLANCE ............................................................................................................... 18
8.2 AIR QUALITY MONITORING......................................................................................... 18
CHAPTER 9 CLEANING AND MAINTENANCE ...............................................................................................19
9.1 INITIAL CLEANING ......................................................................................................... 19
9.2 RECLEANING.................................................................................................................... 19
9.3 KEY POINTS OF ACM MAINTENANCE........................................................................ 19
CHAPTER 10 EMERGENCY PROCEDURES.....................................................................................................20
CHAPTER 11 WASTE DISPOSAL ........................................................................................................................21
CHAPTER 12 RECORD KEEPING.......................................................................................................................22
12.1 SHIPPING MANIFESTS .................................................................................................. 22
12.2 MEDICAL RECORDS...................................................................................................... 22
12.3 TRAINING RECORDS..................................................................................................... 22
12.4 OPERATIONS AND MAINTENANCE RECORDS ....................................................... 22
12.5 OTHER FORMS................................................................................................................ 22
APPENDIX A.............................................................................................................................................................24
DEFINITIONS/ACRONYMS AND ABBREVIATIONS ......................................................................................24
ACRONYMS/ABBREVIATIONS ...........................................................................................................................25
LIST OF TABLES
2-1 Asbestos Management Team Members ...........................................................................11
LIST OF FIGURES
4.1 Asbestos Warning Sign ...................................................................................................14
4.2 Asbestos Warning Label...................................................................................................14
APPENDIX
A Definitions/Acronyms and Abbreviations........................................................................24
B PCD Building Demolition List.........................................................................................22

UNCLASIFIED
Page3
CHAPTER 1
INTRODUCTION
1.1 Purpose
This plan provides policies and procedures for maintaining the Asbestos Program for Pueblo
Chemical Depot (PCD) and outlines specific organizational responsibilities. This plan is
applicable to all military and civilian personnel assigned to the depot, as well as all contractors
and visitors.
1.2 Overview
Asbestos containing materials (ACM) were once widely used in the construction industry. While
the use of ACM in new building systems has ceased for most major applications, the presence of
ACM in older buildings is widespread. At PCD, ACM is present in older buildings in the form
of pipe insulation, sprayed-on fire proofing, acoustic insulation and transite flooring and walls.
In most cases, ACM does not pose a health hazard if left undisturbed. Nevertheless, activities
that have the potential to disturb ACM must be carefully managed to prevent fibers from
becoming airborne and creating an inhalation hazard.
Department of Defense (DOD) policy with regard to ACM is to manage ACM in a manner
protective of human health and the environment, and to comply with all applicable Federal, State
and local laws and regulations governing ACM hazards. Therefore, unless it is determined by
competent authority that the ACM in the property does pose a threat to human health at the time
of transfer, all property containing ACM will be conveyed, leased or otherwise disposed as is.
1.3 Goals
The PCD Asbestos Management Program is designed to protect the health and safety of all
persons who may come into contact with on-site ACM and to comply with regulations set forth
by the U.S. Army, the U.S. Environmental Protection Agency (EPA), the Occupational Safety
and Health Administration (OSHA), and all appropriate state and local regulatory agencies.
The overall goals of the PCD Asbestos Program are as follows:
• Identify/locate all ACM not already listed on the Asbestos Survey Report (Pickering
Report) dated November 6, 1992.
• Maintain existing ACM that is in good condition.
• Remove significantly damaged ACM.
• Ensure the proper cleanup of any previously released asbestos fibers.
• Prevent the further release of fibers.
• Monitor, over time, the condition of ACM.
• Prevent personnel exposure to harmful asbestos levels
• Ensure compliance with applicable policies, rules, regulations and laws

• Ensure asbestos workers and other potentially exposed employees are adequately
trained
1.4 Regulatory Drivers
Key regulations and Army policies that are pertinent to the Asbestos Management Plan are
summarized below:
1.4.1 Occupational Safety and Health Administration (OSHA)
29 CFR 1926.1101 Construction Standards for Asbestos
Applies to individuals involved in construction, renovation, and demolition activities, establishes
a Permissible Exposure Limit (PEL) of 0.1 fibers per cubic centimeter of air (f/cc) as an eight-
hour time-weighted average (TWA) and an Excursion Level of 1.0 f/cc as averaged over a
sampling period of 30 minutes.
Dictates engineering controls and personal protective equipment requirements for individuals
involved with asbestos related work and establishes requirements for medical surveillance and
recordkeeping.
29 CFR 1910.1001 General Industry Standards for Asbestos
Establishes the same PEL and Excursion Limit as outlined in 29 CFR 1926.1101 (Construction
Standard). Scope applies to all occupational exposures to asbestos not specified in the
Construction Standard.
1.4.2 ENVIRONMENTAL Protection Agency (EPA)
40 CFR 61, Subpart M, National Emission Standard for Hazardous Air Pollutants (NESHAP)
Establishes standards for renovation or demolition activities which will impact a combined
quantity of asbestos containing material in excess of 260 linear feet, 160 square feet or 35 cubic
feet. Standards address notification requirements, work practices, and waste disposal
requirements.
40 CFR 763, Subpart G, Worker Protection Rule
This regulation applies the OSHA standards to government employees who are not covered by
the OSHA Asbestos Standards. This regulation considers the handling and removal of ACM in
schools and public buildings.
1.4.3 DEPARTMENT of Transportation Regulations (DOT)
49 CFR 173.216
This regulation establishes labeling, packaging, and transportation requirements for asbestos
containing materials.
1.4.4 UNITED States Army (USA)
AR 200-1, Chapter 9, Environmental Protection and Enhancement (Asbestos Management)
(December 13, 2007)
Requires Army installations, activities, and tenants to comply with all legally applicable and
appropriate Federal, state, and local laws and regulations. Excludes asbestos from all
procurements and uses where asbestos-free substitute materials exist. Establishes and executes
Asbestos Management Plans (AMPs). Establishes Asbestos Management Teams (AMTs).

UNCLASIFIED
Page5
Program and budget resources to identify, manage, and control exposure to asbestos. Conducts
periodic installation surveys to identify the existence, extent, and condition of all asbestos.
Conducts asbestos surveys in all housing units and in those buildings that will be renovated,
demolished, or transferred from Army use.
AR 420-70
Establishes facility policy for management of hazardous building materials in a manner that is
protective of human health and the environment.
Public Works Technical Bulletin 420-70-8
Provides technical information on asbestos management.
1.4.5 State of Colorado
Regulation No. 8, The Control of Hazardous Air Pollutants, Part B, The Control of Asbestos
(Section V.A) (2008)
Establishes accreditation, certification, and training requirements for asbestos contractors,
workers, supervisors, inspectors, management planners, and project designers working in public
and commercial buildings in the State of Colorado. Establishes permit and notification
requirements for asbestos abatement projects.
1.4.6 Environmental Protection Agency (EPA)
40 CFR Part 60, Appendix A METHOD 22 - Visual Determination Of Fugitive Emissions From
Material Handling Sources (July 1, 1991).
Establishes visual observation of fugitive emissions produced during material processing,
handling, and transfer operations where asbestos may be involved. Chapter 2

CHAPTER 2
ASBESTOS MANAGEMENT TEAM
The Asbestos Management Team (AMT) is comprised of the following appointed individuals:
• Chief, Environmental Management Office (EMO)
• Directorate of Public Works (DPW)
• Directorate Risk Management
• Industrial Hygienist
• Competent Medical Authority (CMA2)
• Environmental Protection Specialist
The Installation Commander will delegate responsibility to an Asbestos Program Manager
(APM). The Public Affairs Office (PAO), the EMO, the Safety Office, Directorate of Public
Works, Industrial Hygienist, and the PCD Legal Representative will serve as additional subject
matter experts as necessary. The AMT will brief the Installation Commander on an as-needed
basis.
2.1 Installation Commander
The Installation Commander is responsible for the overall management of the Program. The
Installation Commander will:
• Establish and execute an Asbestos Program in support of the Department of the Army
(DA), Army Materiel Command (AMC), and Chemical Materials Agency (CMA1)
asbestos management policies.
• Program and budget for adequate resources to execute effective management programs.
• Appoint a staff member as Asbestos Program Manager.
2.2 Asbestos Program Manager
The Asbestos Program Manager shall perform the following activities:
• Ensure that the Asbestos Program is available for inspection by employees, regulatory
agencies, effected employees and off-site neighbors.
• Ensure that all ACM abatement complies with applicable EPA, OSHA, state, and local
laws and regulations.
• Support coordination of PCD’s efforts with parties who may be involved in ACM
management, e.g. ensure necessary permits are acquired. Ensure regulatory agencies are
notified of planned asbestos abatement activities.
• Support the investigation of source(s) of debris found by the custodial or maintenance
staff.
• Maintain records of all known ACM remaining within structures and all work related to
ACM.

UNCLASIFIED
Page7
• Maintain a system to retain all records pertaining to ACM for 30 years after the removal
of the last ACM or until facilities are turned over for private use.
• Visit the work site when ACM repair, maintenance, or removal is initiated and
periodically thereafter to verify performance according to the requirements of this
Asbestos Program.
• Inform the Industrial Hygienist of any operations or situations that could expose Depot
employees or residents to asbestos concentrations above the action level.
2.3 Environmental Management Office (EMO)
The Environmental Management Office shall perform the following activities:
• Ensure that an Asbestos Program has been developed and is maintained. Update this
program when conditions at PCD change.
• Ensure ACM survey results, plans, and records are recorded in the document tracking
center.
• Provide technical oversight for activities involving asbestos operations, maintenance,
abatement, and disposal.
• Ensure that the activities of any person who performs asbestos related work, or who
develops and implements response actions (including this program) are carried out in
accordance with the provisions of all applicable state, local, and federal regulations.
• Coordinate abatement activities with the National Environmental Protection Act (NEPA)
Coordinator as appropriate.
2.4 Preventive Medicine
The IH and Competent Medical Authority (CMA2) responsibilities are:
• To advise on selection of personal protective equipment for abatement projects and
provides technical assistance.
• To receive and investigate asbestos related employee/occupant complaints of unsafe
working or living conditions. Provide appropriate asbestos surveillance examinations for
eligible federal or DA civilians in accordance with DA, OSHA, and consensus standards.
• Sampling results that document exposure or potential exposure to Depot employees must
be reviewed by the Depot Industrial Hygienist. The IH will make the appropriate
documentation of such sampling results.
2.5 Public Affairs Office (PAO)
The Public Affairs Office is responsible for:
• Informing personnel, including contractors and lessees, about asbestos abatement
projects. Notification of affected personnel must be done well in advance of the
commencement of asbestos abatement projects.

2.6 CMA1 Legal Representative
The CMA1 Legal Representative will be consulted on any liability or regulatory compliance
issues relating to asbestos abatement projects.
2.7 Risk Management Directorate (RMD)
RMCD is responsible for the following:
• Inform the CMA2 and IH of any operation that could expose employees to asbestos above
the action level.
• Assist in all safety matters related to asbestos management.
• Provide expertise in complying with asbestos safety-related federal, state, and local
requirements. Receive and investigate asbestos related employee/occupant complaints of
unsafe working or living conditions.
2.8 Directorate of Public Works (DPW) is responsible for the following:
• Inform facility occupants of building inspections, response actions, and post-response
activities including periodic surveillance and activities that are planned or are in progress.
• Investigate source(s) of debris found by the custodial or maintenance staff.
• Budgeting for asbestos abatement contractor support services.
• Ensure that all contractors and building maintenance workers who may come in contact
with friable ACM are informed of the Asbestos Program.
• Ensure that asbestos abatement contractors receive a copy of the Asbestos Management
Plan and are briefed by Safety, Industrial Hygiene, and Environmental.
• Ensure contractors/agencies inform EMO of projects for coordination and compliance.
• Supply EMO with records of ACM activities and update these records as changes occur.
• Ensure that EPA is notified when more than 160 linear feet, or 260 square feet, or 35
cubic feet of ACM will be disturbed as a result of renovation or demolition.
• Coordinate PCD’s efforts with parties who may be involved in ACM management, e.g.,
obtain necessary permits. Inform regulatory agencies of planned asbestos abatement
activities.
• Inform the Industrial Hygienist of any operations or situations that could expose PCD
employees or residents to asbestos concentrations above the action level.
2.9 Training Office
The Training Office is responsible for:
• Programming, budgeting adequate resources, and maintaining records for asbestos
training.

UNCLASIFIED
Page9
2.10 Contractor
2.10.1 Responsibilities
Contractors perform most asbestos-related activities at PCD. The contractor will ensure that a
competent person is designated as an Asbestos Control Team Supervisor for each ACM
maintenance project. This person will:
• Adhere to the provisions of 29 CFR 1926.1101.
• Inspect proposed construction/maintenance project areas as necessary to ascertain the
potential for disturbing ACM.
• Supervise the performance of asbestos-related operations and maintenance activities to
ensure projects are accomplished in a safe, efficient manner that complies with regulatory
standards and protects workers and building occupants.
• Implement the contract company sponsored respiratory protection program.
• Inspect, on a daily basis, the work site and construction area.
• Ensure that employees use the hygiene facilities and observe the required documentation
procedures.
• Ensure that engineering controls are functioning properly.
• Supervise all required contractor employee exposure monitoring.
• Ensure that access to the project area by unauthorized personnel is controlled, warning
signs are in place, and containment barriers are installed and functioning properly.
• Ensure that employees maintain and utilize personal protective equipment in accordance
with appropriate regulatory and program requirements during all asbestos related actions.
• Ensure all notifications are made in accordance with appropriate regulatory and plan
requirements, and air-monitoring support is available prior to the initiation of asbestos
projects.
• Oversee the management of any sampling activity, provide sample containers and ensure
all samples are analyzed by an approved laboratory.
• Ensure that assigned personnel are properly identified, trained, equipped, and medically
certified.
• Implement a medical surveillance program.

2.10.2 Exceptions
• Unless all employees are equipped with supplied air respirators, the contractor must
conduct daily monitoring that is representative of the exposure of each employee working
within a regulated area.
• If statistically reliable measurements from daily monitoring within the regulated area
indicate that employee exposure is below the action level, no further monitoring of these
employees is required.
• Exceptions must be approved by the Environmental Management and Safety Offices.

UNCLASIFIED
Page11
TABLE 2-1
ASBESTOS MANAGEMENT TEAM
Appointed Members
Chief, Environmental Management Office 549-4201
Directorate, Public Works 549-4145
Directorate Fire and Emergency Services 549-4688
Directorate, Risk Management 549-4982
Industrial Hygienist 549-4186
Competent Medical Authority 549-4176
Environmental Protection Specialist 549-4201
Other Members
Asbestos Program Manager 549-4201
Public Affairs Officer 549-4135
Safety Representative 549-4533
CMA1 Legal Representative (410)
436-4652

CHAPTER 3
IDENTIFICATION OF ACM
3.1 Purpose
The identification and documentation of ACM at Pueblo Chemical Depot facilities is critical to
gaining a comprehensive understanding of the scope and magnitude of the ACM issue. This
function includes ensuring that new structures and renovations to existing structures do not use
or introduce more ACM at PCD.
The primary document used to identify asbestos at PCD is the asbestos survey contained in the
Pickering Report. For each project, the Pickering report information is verified prior to
beginning work. Verification consists of site visits and inspections by certified asbestos
inspectors. Records of inspections are maintained with project/contract documents. When ACM
is located that is not identified in the Pickering Report, an addendum will be added to the
Pickering Report and filed for future information.
Demolition projects are the major source of ACM disturbance at PCD. A list of potential
Demolition and Decontamination (D&D) locations is included in Appendix B of this document.
3.2 Renovation and New Facility Certification
Design personnel will ensure that the Scope of Work for all construction projects includes a
requirement that an architect or project engineer responsible for the construction will sign a
statement that no ACM was specified as a building material in any construction document for the
building or, to the best of his or her knowledge, no ACM was used as a building material in the
building.
3.3 Abatement Alternatives
Asbestos abatement is defined as any activity that reduces the risk of exposure to airborne
asbestos fibers. Abatement alternatives will only be selected by a qualified asbestos abatement
contractor in consultation with PCD personnel and the Asbestos Management Team.
The presence of ACM does not, in itself, create a condition that requires removal. Alternatives to
removal are repair, encapsulation, enclosure and Operations and Maintenance (O&M). Each
alternative requires an O&M Program to regularly monitor the condition of the asbestos.

UNCLASIFIED
Page13
CHAPTER 4
BUILDING OCCUPANT NOTIFICATION
4.1 Scope
OSHA requires building owners to notify all employees, contractors, tenants, and prospective
contractors who work within or adjacent to areas containing ACM of the presence, location, and
quantities of ACM. This notification to employees includes the following actions by PCD:
• An area that may have airborne asbestos fiber levels exceeding the permissible exposure
limit (PEL), as defined by OSHA, is identified with an asbestos warning sign (29 CFR
1926.1011.k.7). The PEL is currently set at 0.1 fibers per cubic centimeter (f/cc) TWA or
an excursion level (30 minutes) of 1.0 f/cc.
• Labels must be affixed to installed ACM (29 CFR 1926.1011.k.8)
• All ACM raw materials, waste and debris, or containers in which these substances are
stored must be labeled (29 CFR 1910.1001.j.4).
Building occupant notifications summarizing asbestos removal and repair activities and the
present policy for managing remaining ACM should be posted.
If an asbestos incident occurs, it is particularly important for management to communicate with
affected building occupants and contractors.
4.2 Postings
Labels will be affixed to all products containing asbestos and to all containers containing such
products, including waste containers. Where feasible, installed asbestos products shall contain a
visible label (29 CFR 1926.1101.k.8). Warning signs that demarcate regulated areas shall be
provided and displayed at each regulated area (29 CFR 1926.1101.k.7). Signs shall be posted at
such a distance that an employee may read the signs and take necessary protective steps before
entering the marked area. Examples of warning signs and warning labels are shown in Figures
4.1 and 4.2.

Figure 4.1. Warning Sign
Figure 4.2. Warning Label
CHAPTER 6
DANGER
CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST
CANCER AND LUNG DISEASE HAZARD
REPORT ANY ACM DAMAGE TO
THE ENVIRONMENTAL MANAGEMENT OFFICE X4201
DANGER
CONTAINS ASBESTOS FIBERS
CANCER AND LUNG DISEASE HAZARD
DO NOT ENTER WITHOUT PROPER TRAINING AND PPE
RESPIRATORS AND PROTECTIVE CLOTHING
REQUIRED IN THIS AREA

UNCLASIFIED
Page15
CHAPTER 5
WORK CONTROL SYSTEM
Project planning at PCD will take asbestos management into account. As part of the planning
process for D&D projects, PCD will complete a Facility Inspection Report (FIR) to document
environmental issues including asbestos locations. The FIR will be used by the contractor to
plan for asbestos mitigation.
The Environmental Checklist for Work Orders and Contract Proposals is used to identify
projects or actions that will require additional environmental analysis or documentation. The
checklist identifies asbestos issues. If necessary, a Record of Environmental Consideration
(REC) will be prepared by the proponent and approved by EMO in order to satisfy the
requirements of the NEPA.
If disturbance of ACM is intended or likely, an asbestos abatement plan will be developed under
the supervision of the Asbestos Program Manager. A licensed and qualified contractor will then
be engaged to perform the abatement.
The Asbestos Program Manager will be notified in advance of all asbestos-related projects.
Contractors will provide written notification and appropriate fees to EPA Region VIII and the
Colorado Department of Public Health and Environment (CDPHE). Design personnel will
ensure all contract specifications include appropriate State and Federal notifications.

CHAPTER 6
TRAINING
Contractors will provide appropriately trained workers for PCD specific projects. Certificates, as
proof of training, are required for project records.
6.1 Asbestos Awareness Training
PCD employees who may be exposed to asbestos in excess of the PEL shall participate in
Asbestos Awareness training. Training should be provided before or during initial assignment
and at least annually thereafter. The awareness training will be conducted by an asbestos
consultant, PCD Safety Office, or the Training Office. Awareness training should include the
following topics:
• Methods of recognizing asbestos
• Health effects associated with asbestos exposure including the relationship between
smoking, asbestos exposure, and lung cancer.
• Types of operations that could or would result in exposure to asbestos.
• Appropriate methods of minimizing exposure, including engineering controls, work
practices, and personal protective equipment (PPE).
• Purpose, use, fitting instructions and limitations of respirators.
• Medical surveillance program requirements
• The requirements for posting signs and affixing labels
• The names, addresses and phone numbers of organizations that provide smoking
cessation programs
6.2 Advanced Asbestos Training
Asbestos workers may participate in advanced training commensurate with assigned
responsibilities. The following courses, presented by CDPHE-approved training providers, are
recommended:
• Supervisor/Contractor Course (40 hours).
• Asbestos Inspector Course (24 hours).
• Management Planner Course (16 hours).
• Project Designer Course (40 hours).
• Air Monitoring Specialist Course (24 hours).
• NIOSH 582 Course (40 hours).
• Annual refresher courses are required to maintain certification for all levels of training.

UNCLASIFIED
Page17
CHAPTER 7
RESPIRATORY PROTECTION PROGRAM
7.1 Purpose
Exposure to airborne asbestos can be minimized though the use of proper respiratory protection.
As airborne fiber concentrations increase the protection factor must also increase. This is
accomplished by a change in respirator class from half-face piece to full-face piece to supplied
air. Single-use, disposable respirators are not used per 29 CFR §1926.1101 (h).
7.2 Pueblo Chemical Depot Respirator Program
The PCD Respiratory Protection Program (PCD-R 40-20) covers all types of respiratory
protection, including asbestos, if needed.
7.3 Contractor Respirator Program
All contract employees who are engaged in asbestos-related activities will be governed by their
company policies and procedures regarding use of respirators. PCD is not responsible for
activities such as fit testing, inspection, and maintenance of contract employees’ respirators.
Before any asbestos activities take place by contract employees at PCD, the contractor will
provide a copy of their respirator program and all pertinent information to the Safety Office for
review. PCD’s Safety Office will review and evaluate the contractor’s respirator program to
ensure compliance with all applicable laws and regulations.
If the Safety Office finds that a contractor’s respirator program does not comply with all
requirements at PCD, modifications will be made before the initiation of any asbestos-related
activities.

CHAPTER 8
PERIODIC SURVEILLANCE
8.1 Surveillance
If the building occupant or other party discovers that the condition of any ACM has deteriorated,
the Asbestos Program Manager will be notified as soon as possible. CDPHE Certified personnel
will then investigate to determine whether remedial action is required to prevent a health hazard.
The individual conducting the inspection must:
• Visually inspect all areas identified as ACM or assumed ACM.
• Inform the AMT when damage to ACM is observed and/or when debris is cleaned up.
• Record the date of the surveillance, his or her name, and any changes in the condition of
the materials.
8.2 Air Quality Monitoring
Contractors will provide an air quality monitoring professional to perform air quality monitoring.
A sampling strategy will be developed by the professional and approved by the Asbestos
Program Manager before air sampling begins. Air monitoring will be accomplished in
accordance with 29 CFR 1926.1101. Air samples will be analyzed by a laboratory that has
current accreditation by the American Industrial Hygiene Association (AIHA), that maintains
acceptable performance in the National Institute for Occupational Safety and Health (NIOSH)
Proficiency Analytical Testing (PAT) program, and that is certified by the National Voluntary
Laboratory Accreditation Program (NVLAP). Air monitoring performed by contractors shall
comply with State of Colorado and applicable federal requirements.

UNCLASIFIED
Page19
CHAPTER 9
CLEANING AND MAINTENANCE
9.1 Initial Cleaning
Contract personnel specifically trained in asbestos maintenance or an asbestos abatement
contractor will conduct an initial cleaning immediately after a response action is completed. The
purpose of initial cleaning is to remove airborne asbestos fibers that may have been deposited on
surfaces. If an area containing ACM is uncovered during renovation, an asbestos abatement
contractor should remove the materials immediately.
All areas of friable ACM and damaged, or significantly damaged, thermal system insulation that
contains asbestos must undergo an initial cleaning. Newly exposed areas of ACM uncovered
during renovation work must also undergo initial cleaning. In order to prevent further fiber
release, cleaning must be performed using techniques that will not release fibers into the air or
damage the ACM.
9.2 Recleaning
Contract personnel specifically trained in asbestos maintenance or an asbestos abatement
contractor will conduct recleaning operations. Recleaning consists of periodic or routine
cleaning. It uses the same procedures as the initial cleaning and is implemented either on a
regular schedule or when needed. The frequency of recleaning depends on the extent of the
ACM within the facility and the level of contamination.
9.3 Key Points of ACM Maintenance
Access to pipe fittings or sections of pipe may be necessary from time to time. When such work
is necessary, maintenance personnel must contact the Asbestos Program Manager so that the
work can be coordinated with an asbestos removal contractor. When removing insulation to gain
access, care must be taken to avoid release of asbestos fibers. Any individual performing such
activities must, at a minimum, comply with the recommended practices for small-scale, short-
term projects contained in 29 CFR 1926.1101 and 40 CFR 61 subpart M.
Mechanical disturbance of ACM should be avoided because activities such as cutting, drilling,
grinding, sanding, or hammering may cause significant damage and lead to airborne fiber
release. When stripping flooring, follow the guidelines in 29 CFR 1926.1101 (l) (3). If asbestos
removal is necessary, a consultant should be contacted to develop an asbestos abatement plan in
conjunction with the Asbestos Program Manager. A licensed and qualified contractor will
perform the abatement.

CHAPTER 10
EMERGENCY PROCEDURES
In the event of accidental damage to ACM due to roof leaks, broken water lines, improper
maintenance, fire, or any other cause, qualified maintenance personnel should perform the
following activities:
• Stop work and notify the Asbestos Program Manager, the Public Works Office, and the
Safety Office immediately.
• Spill response actions will be conducted in accordance with the Installation Spill Control
Plan (ISCP).
• Evacuate all persons from the affected area.
• Shut down the HVAC system servicing the affected area, and seal all vents in the area of
the release.
• Isolate the area by closing and locking doors and windows and sealing them with
polyethylene sheeting and duct tape. Use appropriate asbestos warning signs on the
barriers.
• A trigger area of at least 80 linear meters (260 linear feet) on pipes or at least 15 square
meters (160 square feet) on other facility components
Personnel that may have been exposed (potentially or actually to asbestos above OSHA PEL
limits) will need to report to the PCD Occupational Health Clinic and complete required
medical questionnaires, such as DD Form 2493–1 (Asbestos Exposure, Part I–Initial
Medical) and/or DD Form 2493-2 (Asbestos Exposure, Part II-Periodic Medical
Questionnaire). It is also recommended that these personnel complete a CA-2, Notice of
Occupational Disease, through the US Department of Labor for claims and compensation of
future health issues caused by such exposure.
• In the event of a medical emergency, call 911 (from a cell phone call 549-4911). The
PCD Fire Department will respond. The Operations Center and the Fire Department will
co-ordinate emergency response and medical assistance.
• For extensive clean-up operations, consult a certified asbestos abatement contractor.
NOTE!
3 square feet was quoted form Public Schools
requirement

UNCLASIFIED
Page21
CHAPTER 11
WASTE DISPOSAL
The Colorado Department of Public Health and Environment has in-state authority to regulate
asbestos under the Clean Air Act and the Resource Conservation and the Recovery Act (RCRA).
The Hazardous Materials and Waste Management Division and the Air Pollution Control
Division share regulatory responsibility for asbestos. The Air Pollution Control Division
regulates inspection and assessment activities as well as asbestos abatement. The Hazardous
Materials and Waste Management Division regulates the proper disposal of asbestos waste in
Colorado.
All asbestos waste will be disposed in a manner that complies with Colorado Regulation #8-Part
B, 40 CFR 61 Subpart M, DOD 4160.21-M, and AR 200-1. The abatement contractor will
handle disposal from abatement activities and will be responsible for transporting the ACM
waste offsite on a daily basis.
Non-friable asbestos that is damaged, to the extent that it can be crumbled or reduced to a
powder by hand pressure when dry, must be handled and packaged like friable asbestos waste.
Resilient floor tile, adhesive sheet vinyl flooring, roof felts, asphalt tiles, transite roofing
shingles, transite siding, and asbestos insulated pipe are considered non-friable forms of asbestos
unless they are or will be damaged during demolition or renovation.
Waste ACM must be placed in air-tight and leak-proof containers to ensure that no visible
emissions occur during handling. Typically, the material is placed into 6-mil-thick plastic bags.
Sharp objects should be placed in puncture-proof containers. Double bagging of waste is
recommended to ensure safe handling. Each waste ACM container must have a warning label as
outlined in Chapter 4 of this document (Figure 4.2). For transportation, label containers with the
name of the waste generator and the location of the waste generation. Waste ACM containers
should be stored in a secured area. EMO waste management personnel will sign manifests for
waste disposal.

CHAPTER 12
RECORD KEEPING
The Asbestos Program Manager will maintain copies of all forms and documentation involving
asbestos. The following documents are part of the Asbestos Program and will be retained at
Pueblo Chemical Depot.
12.1 Shipping Manifests
A receipted copy of the “Waste Origin-Waste Disposal” form for the shipment of ACM will be
maintained, along with other disposal paperwork, in the Document Tracking Center (DTC) for a
minimum period of 2 years. The DTC will furnish upon request, and make available for
inspection, all records required under 40 CFR 61.150.
12.2 Medical Records
Medical exam records (as required in accordance with 29 CFR 1910.1001 and 29 CFR
1926.1101 or other applicable OSHA regulations) will be kept on file by the CMA2 for all
employees who are engaged in asbestos work or who may have been exposed to asbestos fibers
in excess of 0.1 f/cc TWA or an excursion level of 30 minutes at 1.0 f/cc. All records of
measurements taken to monitor employee exposure to asbestos must be maintained for the
duration of employment plus 30 years.
12.3 Training Records
For each person requiring asbestos training, the Training Office will keep on file the person’s
name, job title, date training was completed, type of training, location of the training, and
number of hours completed. Training records must be maintained for the duration of
employment plus 1 year.
12.4 Operations and Maintenance Records
All records should be copied to the PCD document tracking center for archiving.
D&D project files are maintained with contract documents at the DPW. These files may contain
start and completion dates of the work, names and addresses of all contractors involved, their
state/EPA accreditation numbers, and, if ACM is removed, the name and location of the ACM
storage or disposal site. A written description of preventive measures and response actions
including the methods, the location where the preventive measure was taken and reasons for
selecting the measure or action will also be maintained.
Building and facility owners shall maintain records of all information required pursuant to 29
CFR 1910.1001 concerning the presence, location and quantity of ACM and Presumed ACM
(PACM) in the building/facility. Such records shall be kept in the DTC for the duration of
ownership and shall be transferred to successive owners.
12.5 Other Forms
The DTC will maintain records of all asbestos incidents and activities. The DPW will maintain
records of asbestos abatement done in conjunction with building demolition and other contract
projects.

UNCLASIFIED
Page23
Records should be made available upon request to appropriate OSHA representatives in
accordance with 29 CFR 1910.1001 and 29 CFR 1926.1101 or other applicable federal, state, or
local laws. Sampling results and medical records should be made available to appropriate
affected employees, former employees, and designated representatives in accordance with 29
CFR 1910.1001 and 29 CFR 1926.1101 or other applicable federal, state, or local laws.
Due to potential liability issues and concerns associated with asbestos, all employee records
(training and medical) will be kept on file for duration of employment plus 30 years.

APPENDIX A
DEFINITIONS/ACRONYMS AND ABBREVIATIONS
Abatement – The act of removing, encapsulating, enclosing, or repairing asbestos containing
materials.
Asbestos – The asbestiform varieties of serpentinite (Chrysotile), riebeckite (crocidolite),
cummintonite-grunerite, anthophyllite, and actinolite-tremolite, and any of these minerals that
has been chemically treated and/or altered.
Asbestos Containing Material – Any material containing greater than (>) 1 percent asbestos.
Competent Person – One who is capable of identifying existing asbestos hazards in the
workplace and selecting the appropriate control strategy for asbestos exposure per 29 CFR
1926.1101 (b), 29 CFR 1926.23 (f).
Demolition – The wrecking or taking out of any load-supporting structural member of a facility,
together with any related handling operations or the intentional burning of any facility.
Encapsulation – The treatment of asbestos containing material with a material that surrounds or
embeds asbestos fibers in an adhesive matrix to prevent the release of fibers.
Enclosure – An airtight, impermeable barrier around an asbestos containing material to prevent
the release of fibers.
Friable – The ability of a material, when dry, to be crumbled, pulverized, or reduced to powder
by hand pressure.
Removal – All operations, including demolition operations, where asbestos containing material
is taken out or stripped from structures or substrates.
Renovation – Altering a facility or one or more facility components in any way, including the
stripping or removal of asbestos containing material, from a facility component.
Repair – Overhauling, rebuilding, reconstruction or reconditioning of structures or substrates
including encapsulation or other repair of asbestos containing material attached to structures or
substrates.
Surfacing Material – Material such as acoustical plaster on ceilings and fireproofing materials
on structural members that is sprayed on, troweled on or otherwise applied to surfaces for
acoustical, fireproofing, or other purposes.
Suspect Material – A material which, based on its age, use, appearance, and texture, is
suspected to contain asbestos.
Thermal System Insulation – Material applied to pipes, fittings, boilers, breeching, tanks, ducts
or other interior structural components to prevent heat loss, heat gain, water condensation, or for
other purposes.

UNCLASIFIED
Page25
ACRONYMS/ABBREVIATIONS
ACM – Asbestos Containing Material
AHERA – Asbestos Hazard Emergency Response Act
AIHA – American Industrial Hygiene Association
AMC – Army Materiel Command
AMT – Asbestos Management Team
AMP – Asbestos Management Plan
APM – Asbestos Program Manager
BRAC – Base Realignment and Closure
CDPHE – Colorado Department of Public Health and Environment
CMA1 – Chemical Materials Agency
CMA2 – Competent Medical Authority
D&D – Demolition and Decontamination
DA – Department of the Army
DOD – Department of Defense
DOT – Department of Transportation
DPW – Directorate of Public Works
DTC – Document Tracking Center
EMO – Environmental Management Office
EPA – Environmental Protection Agency
f/cc – fibers/cubic centimeter
HEPA – High Efficiency Particulate Air
IH – Industrial Hygienist
ISCP – Installation Spill Control Plan
NEPA – National Environmental Protection Act
NESHAP – National Emission Standard for Hazardous Air Pollutants
NIOSH – National Institute for Occupational Safety and Health
NVLAP – National Voluntary Laboratory Accreditation Program
O&M – Operations and Maintenance
OSHA – Occupational Safety and Health Administration
PACM – Presumed Asbestos Containing Material
PAO – Public Affairs Office

PAT – Proficiency Analytical Testing
PCD – Pueblo Chemical Depot
PEL – Permissible Exposure Limit
PH – Public Health
PPE – Personal Protective Equipment
PUDADA – Pueblo Depot Activity Development Authority
RCRA – Resource Conservation and the Recovery Act
REC – Record of Environmental Consideration
RMD – Risk Management Directorate
TI – Thermal Insulation
TWA – Time Weighted Average
USACE – U. S. Army Corps of Engineers

UNCLASIFIED
Page27
APPENDIX B
PCD BUILDING DEMOLITION LIST

U.S. ARMY CHEMICAL MATERIALS AGENCY
ASBESTOS MANAGEMENT PLAN
December 2011
Approval Page
Prepared by:
Keith L. Phillips Date
Environmental Management Office
Reviewed by:
Date
Chief, Environmental Management Office
Concurrences:
Date
Safety Officer
Date
Director, Risk Management Directorate
Date
Director, Directorate of Public Works

_____________________________________________________ __________________
Date
Chief, Fire Department
______________________________________________________ ________________
Date
Industrial Hygienist
______________________________________________________ ________________
Date
Competent Medical Authority
APPROVED:
_____________________________________________________ _______________
Date
Commanding

Ems example documents

More Related Content

What's hot

Viewers also liked

Similar to Ems example documents

More from Keith Phillips CDR USN Retired

Recently uploaded

Ems example documents