Lead asbestos mgmt plan - ems manual

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

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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]

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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.

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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

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

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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.

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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

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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.

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• 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.

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• 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.

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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.

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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).

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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.

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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.

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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.

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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).

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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.

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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.

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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

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

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ASBESTOS MANAGEMENT PLAN
Prepared by
Pueblo Chemical Depot Environmental Management Office
December 2011

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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

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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

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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).

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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.

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• 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.

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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.

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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.

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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

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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.

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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.

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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

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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.

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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:
Kathryn R. Cain Date
Chief, Environmental Management Office
Concurrences:
Randy Wojtala Date
Safety Officer
Patricia J. Steranka Date
Director, Risk Management Directorate
Eddie Dunn Date
Director, Directorate of Public Works

_____________________________________________________ __________________
Wesley Huntley Date
Chief, Fire Department
______________________________________________________ ________________
John Woodard Date
Industrial Hygienist
______________________________________________________ ________________
Dr. Robert W. Weien Date
Competent Medical Authority
APPROVED:
_____________________________________________________ _______________
TIMOTHY M. GREENHAW Date
LTC, CM
Commanding

UNCONTROLED IF PRINTED PCD EMS Manual
1-1
December 2011
Pueblo Chemical Depot
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.

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