STANDARD OPERATING PROCEDURES

MANIFEST REQUIREMENTS AND PROCEDURES

FOR:

United States Army Garrison (USAG) Alaska *Large Quantity Generator

Directorate of Public Works

Environmental Division

March 2025

1. Purpose:

a. This Standard Operating Procedure (SOP) is intended to outline the responsibilities and procedures associated with the disposal of regulated, non-regulated and or recycled waste generated on USAG Alaska property that requires a Manifest, Land Disposal Restriction (LDR) and/or Bill of Lading (BOL).

b. This SOP ensures compliance with all Federal, State, and local laws and regulations.

2. Applicability:

a. All personnel assigned, attached, or employed by the USAG Alaska, Fort Wainwright tenant organizations, or partners involved in generating, managing and or disposing of regulated, non-regulated and or recycled waste generated on USAG Alaska property.

b. All organizations subject to this SOP will participate in and fully support all installation internal and external assessments, inspections and audits and implement corrective action upon notification.

3. References: These regulations require Waste Manifests to be signed by a delegated representative of the USAG Alaska Garrison Commander that has been trained and certified. Delegated representative of the USAG Alaska Garrison Commander will be appointed in writing.

a. 40 CFR 262, Standards Applicable to Generators of Hazardous Waste, 19 March 2025

b. 40 CFR 264, Subpart E-Manifest System, Recordkeeping, and Reporting, 24 March 2025

c. 49 CFR 100-180, Hazardous Material and Oil Transportation, 3 March 2025

d. 49 CFR 171, Hazardous Materials Regulations, 3 March 2025

e. 49 CFR 172, Hazardous Materials Table, Special Previsions, Hazardous Materials Communications, Emergency Response Information, Training Requirements, and Security Plans, 3 March 2025

f. 49 CFR 176, Carriage by Vessel, 3 March 2025

g. 49 CFR 177, Carriage by Public Highway, 3 March 2025

h. 49 CFR 300-399, Federal Motor Carrier Safety Administration, Department of Transportation, 3 March 2025

i. DTR 4500.9-R, Part II, Defense Transportation Regulation, Cargo Movement, 5 March 2025

j. USAG Alaska, Fort Wainwright #37, Environmental Policy and Procedures

4. Responsibilities:

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

(1) Attend initial Hazardous Waste Manifesting/ DOT training and refresher training every other year thereafter. Obtain certification and store digitally on DPW shared drive.

(2) Provide Delegation of Authority letter to the USAG Alaska Garrison Commander for approval and signature.

(3) Review and approve waste sample results, waste profiles, and manifests received from Project Managers.

(4) Conduct on-site quality control (QC) inspection when deemed necessary prior to removal order to ensure waste and its containers are in good shippable condition and if applied, the shipping labels are correct; meet all applicable regulatory requirements and standards.

(5) Will be physically present for and during waste removal to verify waste and its containers meet all applicable regulatory requirements and standards.

(6) Provide signature on manifest, LDR and or BOL after verifying waste and its containers have been loaded and meet all applicable regulatory requirements and standards.

(7) Retain copy(s) of manifest, LDR and or BOL and any relevant waste disposal documentation for three years; documents will be stored at the DPW Environmental Division.

(8) Submit and or provide any required documentation associated with manifested waste to the Environmental Protection Agency (EPA) as required or requested.

b. Project Managers (PM):

(1) Act as the primary point of contact for all waste management activities related to the project, ensuring compliance with all Federal, State, and local laws and regulations.

(2) For non-DPW projects, the non-DPW PM will coordinate with DPW PM to ensure project is in line with USAG Alaska protocols.

(3) Coordinate with contractor to ensure proper waste handling, containerizing, sampling and documentation as applicable.

(4) Obtain and review waste sample results, waste profiles, and manifest from contractor.

(5) Submit all sample results, waste profiles, draft manifest and other applicable documentation to the DPW Environmental Division delegated personnel for review one week prior to scheduling a date for removal of waste.

(6) Coordinate on-site QC inspection prior to removal of waste with DPW Environmental Division delegated personnel.

(7) Coordinate waste removal day and time with DPW Environmental Division delegated personnel.

(8) Coordinate all waste related activities with DPW Environmental Division.

c. Contractors:

(1) Must coordinate with their respective agency’s PM.

(2) Submit all sample results, waste profiles, draft manifest and other applicable documentation to project PM in a clear and organized format, including sample results provided in a spreadsheet with corresponding sample numbers.

(3) Coordinate all waste related activities with project PM.

(4) Ensure proper labeling of waste containers and are visible upon QC inspection.

(5) Obtain Waste Profile from the waste disposal services that will be used for respective project.

(6) Submit waste profile to respective PM for forwarding and approval by DPW Environmental Division delegated personnel.

5. Waste Sampling Requirements:

a. Waste will be analyzed using the Toxicity Characterization Leaching Procedure (TCLP) concentrations, not total concentrations. Results of total concentration analysis of solid waste are not sufficient for completing a hazardous waste manifest.

b. All waste will be sampled using the most current EPA test methods for evaluating solid waste physical chemical methods (SW-846) and/or ADEC directed test methods.

c. Utilize laboratories certified by the National Environmental Laboratory Accreditation Program.

c. All laboratory results and reports will be provided in a spreadsheet with corresponding sample number(s).

6. Waste Profile(s) Requirements:

a. If the Treatment, Storage and Disposal Facility (TSDF) requires a signed profile, it must be approved and signed by the DPW Environmental Division delegated personnel.

b. Waste profiles will be prepared according to the requirements of the designated

TSDF.

c. It is contractors’ responsibility to obtain waste profile from waste disposal services that will be used for respective project.

b. Ensure all supporting documentation has been submitted via email to DPW Environmental Division delegated personnel, this is required before review and signature.

c. Allow a minimum of 24 hours for DPW Environmental Division delegated personnel to review.

7. Manifest Management:

a. Manifest(s) will not be signed before the waste is removed.

b. DPW PM must coordinate with DPW Environmental Division delegated personnel the date and time of waste removal.

c. DPW Environmental Division delegated personnel will be present during the removal of waste and sign manifest, LDR and or BOL at that this time.

8. Manifest Nomenclature:

a. All containers reported on manifest will use the Units of Measure table nomenclature listed below:

(1) G=Gallons

(2) K=Kilograms

(3) L=Liters (liquid only)

(4) M=Metric Tons (1000 Kilograms)

(5) N=Cubic Meters

(6) P=Pounds

(7) T=Tons (2000 pounds)

(8) Y=Cubic Yards

b. All Polychlorinated Biphenyls (PCB) manifests regardless of PCB concentration will list weight in kilograms (K).

c. Tons, Metric Tons, Cubic Meters, and Cubic Yards should only be reported in connection with very large bulk shipments, such as rail cars, tank trucks, or barges.

d. Weight of containers can be actual or estimated weights.

e. All containers reported on manifest will use the Types of Containers table nomenclature listed below:

(1) BA=Burlap, cloth, paper, or plastic bags

(2) CF=Fiber or plastic boxes, cartons, cases

(3) CM=Metal boxes, cartons, cases (including roll-offs)

(4) CW=Wooden boxes, cartons, cases

(5) CY=Cylinders

(6) DF=Fiberboard or plastic drums, barrels, kegs

(7) DM=Metal drums, barrels, kegs

(8) DT=Dump truck

(9) HG=Hopper or gondola cars

(10) TC=Tank cars

(11) TP=Portable Tanks

(12) TT=Cargo tanks (tank trucks)

9. Manifest(s) Information:

a. Generator’s ID Number (EPA):

(1) Fort Wainwright (FWA) -LQG: AK6210022426

(2) Yukon Training Area (YTA)-VSQG: AKR000209841

(3) Donnelly Training Area (DTA)-VSQG: AKR000200089

(4) Black Rapids Training Area (BRTA)-VSQG: AKR000200071

(5) Seward (SRC)-VSQG: AKR000003871

b. Generator’s Name and Mailing Address:

USAG Fort Wainwright Alaska 1046 Marks Rd. # 4500 AMIM-AKP-E Fort Wainwright, AK 99703

c. Generators Phone: (907) 361-6104

d. Generator’s Site Address: Location/address where waste was generated. This can be the building number and street or street and project number. For Non-Hazardous Waste Manifest, add information next to Generator’s Name and Mailing Address in Box 3.

10. Cradle to Grave:

a. Within 30 days of delivery of the waste to the designated facility, the owner or operator of the facility must send one signed and dated copy of the paper replacement manifest to the generator and send an additional signed and dated copy of the paper replacement manifest to the electronic manifest system.

b. A large quantity generator who does not receive a copy of the manifest with the signature of the owner or operator of the designated facility within 45 days of the date the waste was accepted by the initial transporter must contact the transporter and/or the owner or operator of the designated facility to determine the status of the hazardous waste.

c. A large quantity generator must submit an Exception Report to the EPA Regional Administrator for the Region in which the generator is located if he has not received a copy of the manifest with the handwritten signature of the owner or operator of the designated facility within 60 days of the date the waste was accepted by the initial transporter. The Exception Report must include:

(1) A legible copy of the manifest for which the generator does not have confirmation of delivery.

(2) A cover letter signed by the generator or his authorized representative explaining the efforts taken to locate the hazardous waste and the results of those efforts.

d. Upon discovering a significant difference in quantity or type, the owner or operator must attempt to reconcile the discrepancy with the waste generator or transporter (e.g., with telephone conversations). If the discrepancy is not resolved within 20 days after receiving the waste, the owner or operator must:

(1) Generator will immediately submit to the EPA Regional Administrator a letter describing the discrepancy and attempts to reconcile it, and a copy of the manifest or shipping paper at issue.

(2) Beginning on December 1, 2025, immediately submit a Discrepancy Report to the EPA e-Manifest system describing the discrepancy and attempts to reconcile it, and a copy of the manifest or shipping paper at issue. Beginning on December 1, 2025, the EPA will no longer accept mailed paper Discrepancy Reports from facilities.

e. The PM will ensure the DPW Environmental Division delegated personnel receives the final manifest signed by TSDF

f. All waste documentation to include final manifest will be stored at building 3023 for three years.

11. DPW Environmental Division delegated personnel:

(1) Kathleen Gannon, kathleen.a.gannon2.civ@army.mil, (907) 361-6104

(2) Vicki Madick, vicki.l.madick.civ@army.mil, (9070 361-9195

(3) Patrik Sartz, patrik.p.sartz.civ@army.mil, (907) 361-6220 mailto:kathleen.a.gannon2.civ@army.mil mailto:vicki.l.madick.civ@army.mil mailto:patrik.p.sartz.civ@army.mil