Management Plans and Program Documentation

1 October 2001ORARNG Pam 200-1

Chapter 20

MANAGEMENT PLANS AND PROGRAM DOCUMENTATION

20-1. REFERENCES

1. AR 200-1
2. AR 200-2
3. AR 200-3
4. AR 200-4
5. ORARNGR 200-1
6. ORARNGR 210-5
7. ORARNGR 210-6
8. ORARNGR 350-29
9. ORARNGR 385-16
10. ORARNGR 420-47
11. ORARNG Pam 385-10

20-2. SCOPE. The ORARNG Environmental Compliance Program defines requirements for facilities and units, and covers numerous environmental subjects and regulatory issues. The program requires implementation of detailed and comprehensive management plans, as well as actions necessary to achieve regulatory compliance. Requirements are identified in applicable references. Background information and guidance on maintaining compliance, at various levels of the ORARNG, are defined in various chapters of this pamphlet. Management plans, required documentation, and other program guidance are included in this chapter. Annexes are also provided for filing specific information. In this manner, personnel assigned environmental tasks should be able to easily file and find necessary environmental documents.

20-3. BACKGROUND INFORMATION

1. Compliance requirements and responsibilities identified in ORARNGR 200-1 and this pamphlet require the implementation of various management plans, completion of forms and reports, and documentation of compliance activities. This chapter serves as a place-holder for documents required by this pamphlet. To the maximum extent possible, documentation requirements are defined for each annex.

1. DOD and DA regulations often require management plans to achieve regulatory compliance for various environmental subjects. These plans provide site-specific programs to implement applicable regulations. For the most part, AGI-ENV will develop management plans, but implementation often requires action at facility or unit level.

1. Implementation requirements for facilities and units are included in annexes to this chapter. Environmental plans or programs implemented by AGI-ENV (i.e., Environmental Restoration, Real Estate Actions, etc.) are managed by AGI-ENV and coordinated with facilities or units specifically affected by the action or requirement.

1. Federal, state, and local environmental regulations often require written guidance or specific documentation to demonstrate compliance. These requirements are met through the use of Army-required management plans, specific forms described in various chapters of this pamphlet, and documentation prepared and retained at AGI-ENV. In some instances, it might also require the development of unit or facility-specific SOPs.

1. In some instances, AGI-ENV requests the submission of specific information from units and facilities to assist in meeting compliance requirements for the unit or activity, as well as meeting AGI-ENV requirements in reporting to NGB or regulatory agencies.

1. Actions required by this pamphlet, including the completion of all forms and required reporting, must be done to achieve overall compliance.

20-4. ENVIRONMENTAL COMPLIANCE STATEMENT

1. Preparing and implementing management plans, as well as documenting required activities, are key to maintaining the ORARNG Environmental Compliance Program.

1. In order to ensure requirements are understood and achieved, each unit and facility must have access to and be familiar with current copies of references that provide details of required actions. These are available electronically through the Environmental portion of the OMD Website, or through "Outlook" in the RCAS at Public Folders/ AGI - Installations/Environmental/Regulations. They are also available in hard copy (from the print shop). If hard copies are maintained, they should be kept in or with the ECN.

1. In addition to the Environmental Compliance Notebook, the following documents must be used to ensure environmental compliance at the unit and facility level. They are shown in the order required for the various chapters of the Environmental Compliance Notebook:

(1)ORARNGR 350-29, Local Training Areas

(2)ORARNGR 385-16, Asbestos Management Program

(3)ORARNG Pam 385-10, Hazard Communication Program

(4)ORARNGR 420-47, Hazardous Material and Waste Management Plan

(5)ORARNGR 210-6, Installation Spill Contingency Plan

(6)ORARNGR 210-5, Integrated Pest Management Program

(7)ORARNGR 350-25, Integrated Training Area Management

(8)NGR (AR) 385-15, Policies, Responsibilities, and Procedures for Inspection/ Evaluation and Use of ARNG Indoor Firing Ranges

1. This chapter is designed to consolidate documents, establish a simplified filing system, summarize requirements, and identify to the greatest degree practicable who (unit/facility) is affected by each requirement. The contents of this chapter and its annexes cannot be used solely to implement the entire program. Responsibilities and other essential guidance are provided in other references and the preceding chapters of this pamphlet. Assistance from AGI-ENV is also available to ensure requirements are met. Documentation of activities provided in this chapter verifies that applicable requirements are identified and required actions conducted.

20-5. RESPONSIBILITIES

(1) AGI-ENV will:

(a) Provide appropriate guidance in ORARNGR 200-1, this pamphlet, and other ORARNG documents to assist in achieving environmental compliance at every facility and unit.

(b) Require submission of specific information to AGI-ENV and assist EPOCs in document preparation.

(c) Assist EPOCs and State Maintenance Workers in preparing documents and filing items necessary to achieve regulatory compliance.

(d) Prepare, maintain, and distribute reports for the FEMB, as appropriate, to document the status of environmental compliance, and provide a mechanism to track required actions or submittals that are nearing or have exceeded suspense dates.

(2) Unit or Facility EPOC will:

(a) Review ORARNGR 200-1, each chapter and annex of this pamphlet, and identified references to determine all applicable compliance requirements.

(b) Implement management plans and prepare appropriate documentation to demonstrate compliance with environmental regulations.

(c) Submit required reports or other information through command channels.

(3) State Maintenance Worker will:

(a)Review ORARNGR 200-1, each chapter and annex of this pamphlet, and identified references to determine all applicable compliance requirements.

(b) Implement management plans and prepare appropriate documentation to demonstrate compliance with environmental regulations.

(c) Submit required reports or other information through command channels.

(d) Coordinate environmental requirements through AGI-O to AGI-ENV, or as otherwise directed.

20-6. KEY QUESTIONSYESNON/A

1. Has the ORARNG Environmental Compliance Program been implemented? ______

1. Are current, required environmental references available,

either hard-copy or electronically?______

1. Are required forms, information documents or other

necessary data filed at the appropriate annexes?______

20-7. LIST OF ANNEXES

The annexes described in this pamphlet are place-holders for plans; in-use and completed forms; and other required documents. Each annex should contain the following documents, unless they are readily available electronically and can be quickly produced during a regulatory inspection:

Annex A, ENVIRONMENTAL MANAGEMENT AND POINTS OF CONTACT

- Environmental Point of Contact Appointment Orders

-AGO Form 200-1-1, Facility/Unit EPOC Matrix

-Unit Environmental SOP or Other Written Guidance

Annex B, ENVIRONMENTAL DOCUMENTATION

- Draft/Final Environmental Checklists/RECs for Local Training Areas or Other Actions

Annex C, WASTEWATER DISCHARGE PERMITS AND MANAGEMENT

- Waste Water Discharge Permits, Monitoring Results, and Correspondence

- Washrack SOP

-Washrack Maintenance Requirements Requests

-Copies of Correspondence from Regulatory Agencies

Annex D, STORM WATER POLLUTION CONTROL PLANS

- Storm Water Pollution Control Plan for the facility

- Other Storm Water Management Guidance provided by AGI-ENV

Annex E, DRINKING WATER QUALITY MANAGEMENT

- Drinking Water Compliance Testing Results

- Other Drinking Water Guidance Provided by AGI-ENV

Annex F, AIR QUALITY MANAGEMENT

- Air Quality Permits, if Required

- Air Emissions Tracking Report and/or Correspondence

-ODS Technician Certification Forms

-ODS Inventories

-Documentation of Oxygenated Gasoline

Annex G, ASBESTOS MANAGEMENT PLAN

- Facility Asbestos Management Surveys

- Facility Asbestos Management Plan

Annex H, HAZARDOUS MATERIAL MANAGEMENT

- AGO Form 200-1-3, Hazardous Material Inventory

- Copy of Above-Ground Storage Tank Permits, if Appropriate for the Facility

-AGO Form 200-1-4, Heating Oil Storage Tank Monthly Inventory

-AGO Form 200-1-5, Above-Ground Storage Tank Monthly Inspection

-Inventory of Fluorescent Light Ballasts with PCBs

Annex I, SARA TITLE III (EPCRA) REPORTS

- SARA Title III (EPCRA/Tier II) Reports to State Fire Marshal

Annex J, PEST AND PESTICIDE MANAGEMENT

- Completed Pest Control Documentation Forms (see Appendix B, ORARNGR 210-5)

- Completed Pesticide Inventory (see Appendix C, ORARNGR 210-5)

-Completed Pesticide Application Equipment Inventory (see Appx D, ORARNGR 210-5)

-Completed Pesticide Application Record (see Appendix E, ORARNGR 210-5)

-Requests for Pest Management Assistance or Pesticide Application (AGO Form 138)

-Dept. of Agriculture Pesticide Applicator Certification for Facility Personnel

Annex K, HAZARDOUS WASTE MANAGEMENT

- Unit or Facility HW SOP

- Facility EPA/DEQ HW Generator Identification Number (if applicable)

- Hazardous Waste Manifests and/or DA Form 2765s (see Appx M, ORARNGR 420-47)

- Hazardous Waste Manifest Document Register (see Appx M, ORARNGR 420-47)

Annex L, HAZARDOUS WASTE MANAGEMENT REPORTS

- AGO Form 200-1-6, Hazardous Waste Determination Worksheet

- EPA/DEQ HW Generator ID Number Registration Verification Report

-TURHWR Plans/Reports Submitted to DEQ

Annex M, EMERGENCY INFORMATION FORM

- AGO Form 200-1-7, Emergency Information

Annex N, WEEKLY INSPECTION SHEET

- AGO Form 200-1-8, Weekly Inspection Sheet

Annex O, POLLUTION PREVENTION PLANS

- State Pollution Prevention Plan

- Facility Pollution Prevention Plan or Other Information, If Required

Annex P, SOLID WASTE MANAGEMENT

- ORARNG Solid Waste Management Plan

-Facility Solid Waste and Recycling SOP

-Other AGI Guidance on Managing Solid Waste

Annex Q, SPILL CONTINGENCY PLANNING AND REPORTING

- Spill Pollution Control & Countermeasure Plan or Integrated Contingency Plan

-Facility Spill Response Plan (FRSP)

- AGO Form 200-1-9, Spill Incident Report (Completed Forms)

- AGO Form 200-1-10, Transportation Spill Response Card

Annex R, INDOOR FIRING RANGE MANAGEMENT

- Appointment Order for Range Custodian

-Approved Indoor Firing Range SOP

-Documentation of Training for Range Cleaning Personnel

Annex S, RADON AND LEAD-BASED PAINT MANAGEMENT

- Radon and Lead-Based Paint Guidance Provided by AGI

- Radon and Lead-Based Paint Laboratory Analyses

Annex T, NOISE MANAGEMENT AND COMPLAINT PROCEDURES

- AGO Form 200-1-11, Noise Complaint Questionnaire for Complaints Received

-Environmental Noise Management Plan for the Facility

-Environmental Noise Zone Map for the Facility, if not part of an ENMP

-Other Correspondence on Environmental Noise Issues

Annex U, NATURAL RESOURCES MANAGEMENT AND PLANS

- Natural Resource Inventories for the Facility, LTAs, Other Operations Areas

-Integrated Natural Resource Management Plan, as Required

-Endangered Species Management Plan, as Required

- AGI-ENV or Other Guidance on Managing Natural Resources

Annex V, CULTURAL RESOURCES MANAGEMENT AND PLANS

- Resource Inventory for the Facility

-Cultural Resource Management SOP for the facility

-Copy of Correspondence from AGI-ENV or SHPO

Annex W, ENVIRONMENTAL AUDITS, INSPECTIONS AND ENFORCEMENT ACTIONS

- Copy of Applicable Portions of Most Recent ECAS

-Copy of Applicable Portions of Most Recent ICAS (AGO Form 200-1-12)

-Copy of Correspondence from AGI-ENV or higher HQ on Environmental Compliance

-Regulatory Agency Correspondence, Inspections, or Notices of Non-Compliance/Violation

Annex X, TRAINING DOCUMENTATION

- AGO Form 200-1-13, Environmental Training Program Attendance Roster

Annex Y - Reserved for Future Use

Annex Z - Reserved for Future Use

20-8. TECHNICAL ASSISTANCE. Technical assistance relating to management plans or documentation can be obtained from the appropriate program POC in the Environmental Section (AGI-ENV) at the phone numbers noted in each chapter.

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