J2_RSA Policy 200-6.pdf

Redstone Arsenal Waste Management Plan

Policy 200-6

US Army Garrison-Redstone Redstone Arsenal, AL 35898-5000

August 12, 2021

USAG - Redstone Policy 200-6

US Army Garrison

Redstone Arsenal, Alabama 35898-5000

Attachment J2 RSA Policy 200-6 1 May 2023

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TABLE OF CONTENTS

i

TABLE OF CONTENTS

List of Tables and Figures……………………………………………………………………i

List of References……………………………………………………………………………..ii

List of Abbreviations and Acronyms…………………………………………………… ..iii

Contact List ................................................................................................................... iv

Section 1 Introduction ............................................................................................. 1-1

1.1 Purpose and Objective .............................................................................. 1-1

1.2 Applicability ............................................................................................... 1-1

1.3 Implementation ......................................................................................... 1-2

1.3.1 Plan Review ................................................................................... 1-2

1.3.2 Revision Log .................................................................................. 1-3

Section 2 Installation and Regulatory Overview ................................................... 2-1

2.1 General ..................................................................................................... 2-1

2.2 Regulatory Authority .................................................................................. 2-2

2.2.1 Federal Regulations ....................................................................... 2-2

2.2.2 State Regulations .......................................................................... 2-2

2.2.3 Army Regulations ........................................................................... 2-3

2.2.4 Redstone Arsenal Policies ............................................................. 2-3

2.2.5 Waste Minimization…………………………………………………….2-4

2.3 EPA Identification (ID) Number ................................................................. 2-4

2.4 Hazardous Waste Storage Units (HWSU) ................................................. 2-5

2.5 General Hazardous Waste Training Requirements ................................... 2-6

Section 3 Responsibilities ...................................................................................... 3-1

3.1 General ..................................................................................................... 3-1

3.2 Garrison Commander................................................................................ 3-1

3.3 Environmental Quality Control Committee (EQCC) ................................... 3-2

3.4 Chief, EMD (AMIM-REP-E)… ................................................................... 3-2

3.5 Commanders, Directors, and Supervisors (Personal, Civilian, and

Contractors) ................................................................................................ …...3-3

3.6 Environmental Officers .…………………………………………………….......3-4

3.7 Environmental Point of Contacts for SAAs and HWSUs ........................... 3-4

3.8 U.S. Army Redstone Garrison-EMD ......................................................... 3-4

3.9 DLA-DS ..................................................................................................... 3-5

3.10 Chief, Legal Office .................................................................................... 3-5

3.11 Director, AMC-LRC ................................................................................... 3-5

3.12 Commander, Fox Army Medical Center (MCXW-C) ................................. 3-5

3.13 Chief, Garrison Safety (AMIM-RE) ............................................................ 3-6

Section 4 Hazardous Waste Identification and Classification ............................. 4-1

4.1 General ..................................................................................................... 4-1

4.2 Exemptions from Hazardous Waste Definition .......................................... 4-1

4.3 Listed Wastes ............................................................................................ 4-2

4.4 Characteristic Wastes ............................................................................... 4-3

4.5 Redstone Arsenal Waste Identification Requirements .............................. 4-3

Section 5 Hazardous Waste Satellite Accumulation Areas ................................. 5-1

5.1 General ..................................................................................................... 5-1

5.2 Waste Accumulation Quantities ................................................................ 5-1

5.3 Container Management Requirements ..................................................... 5-2

5.3.1 Compatibility .................................................................................. 5-2

5.3.2 General Requirements ................................................................... 5-2

5.3.3 Liquid Waste Container Requirements .......................................... 5-3

5.3.4 Labels and Signs ........................................................................... 5-3

5.4 Security ..................................................................................................... 5-4

Section 6 Hazardous Waste Storage Units <90 day ............................................. 6-1

6.1 Hazardous Waste Storage Units ............................................................... 6-1

6.2 Waste Accumulation ................................................................................. 6-1

6.3 Signage ..................................................................................................... 6-2

6.4 Facility Specifications ................................................................................ 6-2

6.5 Container Management Requirements ..................................................... 6-3

6.5.1 Container Stacking ........................................................................ 6-3

6.5.2 Container Specifications ................................................................ 6-3

6.5.3 Waste and Container Compatibility ................................................ 6-3

6.5.4 Damaged Containers ..................................................................... 6-3

6.5.5 Container Labeling ......................................................................... 6-3

6.6 Inspections ................................................................................................ 6-4

6.7 Recordkeeping ......................................................................................... 6-5

6.7.1 Records that must be kept in the <90 day HWSUs ...................... 6-5

6.7.2 Records that may be kept in a separate work area ...................... 6-5

Section 7 Hazardous Waste Disposal ................................................................... 7-1

7.1 General Hazardous Waste Disposal ......................................................... 7-1

7.2 Preparation for Disposal and Packaging ................................................... 7-1

7.3 Hazardous Waste Turn In Procedures ...................................................... 7-1

7.4 Waste Profiles ........................................................................................... 7-2

7.5 Hazardous Waste Marking and Labeling Requirements ........................... 7-2

7.5.1 General Requirements ................................................................... 7-2

7.5.2 Marking .......................................................................................... 7-2

7.5.3 Labeling ......................................................................................... 7-2

7.6 Turn-In Documentation ............................................................................. 7-3

7.7 Transportation of Hazardous Waste .......................................................... 7-3

7.8 Manifests................................................................................................... 7-4

7.9 Land Disposal Restrictions…………………………………………………….7-5

7.10 Exception Reporting……………………………………………………………7-6

7.11 Recordkeeping………………………………………………………………….7-7

7.12 Hazardous Waste Reporting………………………………………….. ……..7-7

Section 8 Hazardous Waste Analysis Plan ........................................................... 8-1

8.1 General ..................................................................................................... 8-1

8.2 Chain-of-Custody Forms ........................................................................... 8-1

8.3 Characterization Frequency ...................................................................... 8-2

8.4 Unknown Wastes ..................................................................................... 8-2

Section 9 Hazardous Waste Minimization ............................................................ 9-1

9.1 General Waste Minimization .................................................................... 9-1

9.2 Pollution Prevention Plan ......................................................................... 9-1

9.3 Hazardous Materials ................................................................................ 9-2

9.4 EMS Objectives and Targets ................................................................... 9-2

Section 10 Installation Waste Stream Summary ................................................... 10-1

10.1 General .................................................................................................. 10-1

10.2 Hazardous Waste .................................................................................. 10-1

10.3 Non-Hazardous Waste ........................................................................... 10-2

10.4 Universal Waste .................................................................................. 10-2

10.5 Prohibited Items .................................................................................. 10-3

10.6 Polychlorinated Biphenyls ................................................................... 10-4

10.7 Regulated Medical Waste (RMW) ....................................................... 10-4

10.8 Military Munitions…………………………………………………………...10-4

Section 11 Installation Waste Stream Management ............................................. 11-1

Section 12 OBOD Thermal Treatment Facility .................................................... 12-1

12.1 Facility Management ........................................................................... 12-1

12.2 Materials Accepted for Treatment and Disposal .................................. 12-1

12.3 Procedure for Turn-In Materials for Treatment and Disposal............... 12-2

12.4 Operational Range Inspection Assessment Program .......................... 12-3

12.5 Explosive Ordnance Disposal Support Team ...................................... 12-3

Section 13 Spill and Emergency Response Procedures ................................. . 13-1

13.1 General Spill Response ………………………………………………….13-1

13.2 Spill Response and Emergency Procedure……………………………...13-1

13.3 Spill Contingency …………………………………………………………. 13-1

13.4 Spill Contingency Training ………………………………………………. 13-1

13.5 Spill Contingency Supplies……………………………………………......13-2

TABLES AND FIGURES

LIST OF TABLES

Table A Plan Review ................................................................................................. 1-2

Table B Revision Log ................................................................................................ 1-3

Table C Maximum Concentration of Contaminant / TCLP ......................................... 4-3

LIST OF FIGURES

Figure A Contact List………………………………………………………………..…….…vii

Figure B Part B Permitted Hazardous Waste Storage Units…………………………….2-5

Figure C Training Record……………………………………………………………………2-6

Figure D Contingency Quick Reference Guide…………………………………………...D-1

Figure E RSA Red Plan SPCC……………………………………………………………..E-1

Figure F Compatibility Chart……………………………………………………………......F-1

Figure G 49 CFR 172.400…………………………………………………………………..G-1

Figure H Inspection Form DRMS 1713……………………………………………………H-1

Figure I Labels……………………………………………………………………….……....I-1

Figure J ADEM Aerosol Cans…………………………………………………...….…..….J-1

Figure K ADEM Solvent Contaminated Wipes Rule…………………………..….…......K-1

Figure L ADEM Satellite Accumulation of Hazardous Waste……………….…..………L-1

Figure M Flow Chart Waste Management…………………………………………………M-1

Figure N Redstone Arsenal Range Inspection and Assessment……………………….N-1

Figure O Memorandum for Request Satellite Accumulation Area …..……………….O-1

REFERENCES

ii

LIST OF REFERENCES

Code of Federal Regulations Title 40 parts 260 – 299

Code of Federal Regulations Title 49

ADEM Hazardous Waste Program Division 14

Army Regulation 200-1, Environmental Protection and Enhancement

Army Regulation 420-49, Utility Services

DOD 6055.9-STD, Ammunition and Explosives Safety Standards.

EO 13423-- requires Federal agencies to increase solid waste diversion and to maintain cost effective waste prevention and recycling programs.

EO 12780— Federal Agency Recycling and Council on Federal Recycling and Procurement.

EO 13148—Greening the Government through Leadership in Environmental Management.

Redstone Arsenal Hazardous Waste Permit B AL7210020742

Redstone Arsenal Waste Minimization Plan 200-8

Redstone Arsenal Pollution Prevention Plan “P2”

Redstone Arsenal Hazardous Material Management Plan

Redstone Arsenal Red Plan (Spill Prevention, Control, and Countermeasure)

ENV-HW-001 Waste Turn-in Procedure

ENV-HW-002 Management of the Hazardous Waste Storage Facility

ENV-HW-008 Universal Waste Management

ENV-SW-004 Waste Equipment turn-in suspect PCB

ENV-SW-005 Halon Cylinder Turn-in Procedure

ENV-SW-007 Management of Used Oil and Fuel Filters

ENV-HW-006 SAA Management

ENV-HW-011 Recycling Program

RA-0000-A-AMW-PP-001 External SOP for Treatment and Disposal OBOD iii

ABBREVIATIONS AND ACRONYMS

LIST OF ABBREVIATIONS AND ACRONYMS

<90 day HWSU 90-Day Hazardous Waste Storage Unit

<1 year HWSU 1-Year Hazardous Waste Storage Unit

ADEM Alabama Department of Environmental Management

AR Army Regulation

CARC Chemical Agent Resistant Coating

CFR Code of Federal Regulations

CLIN Contract Line Item Number

CPAC Civilian Personnel Advisory Center

CRRC Consolidation, Recycling, and Reuse Center

CY Calendar Year

DA Department of the Army

DLADS Defense Logistics Agency Disposition Services

DoD Department of Defense

DPW Directorate of Public Works

DPW-EMD Directorate of Public Works, Environmental Management Division

EESOH-MIS Enterprise Environmental, Safety, and Occupational Health Management Information System

EMS Environmental Management System

EMSMR Environmental Management System Management Representative

EO Environmental Officer

EOD Explosive Ordnance Disposal

EPA Environmental Protection Agency

EPAS Environmental Performance Assessment System

ESSP Explosive Safety Site Plan

EQCC Environmental Quality Control Committee

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FRH Flameless Ration Heaters

GAA Grease, Automotive and Aviation

HID High Intensity Discharge

HM Hazardous Material

HM/HW Hazardous Material/Hazardous Waste

HMCC Hazardous Material Control Center

HMMP Hazardous Material Management Program

HQDA Headquarters, Department of the Army iii

ABBREVIATIONS AND ACRONYMS

HWMP Hazardous Waste Management Plan

HW Hazardous Waste

HWSAA Hazardous Waste Satellite Accumulation Area

HWSU Hazardous Waste Storage Unit

ID Identification

LBP Lead-Based Paint

LDR Land Disposal Restrictions

LiSO2 Lithium Sulfur Dioxide

LQG Large Quantity Generator

LRC Logistics Readiness Center

MFR Memorandum for Record

NBC Nuclear, Biological, and Chemical

NiCd Nickel-Cadmium

NiMH Nickel Metal Hydride

NOV Notice of Violation

NRC National Response Center

NRMW Non-Regulated Medical Waste

OBOD Open Burn Open Detonation

ORAP Operational Range Assessment Program

P2 Pollution Prevention

PAO Public Affairs Office

PCB Polychlorinated Biphenyls

POC Point of Contact

POL Petroleum, Oil, and Lubricants

PPE Personal Protective Equipment

RCRA Resource Conservation and Recovery Act

RMW Regulated Medical Waste

RSA Redstone Arsenal

SJA Staff Judge Advocate

SOP Standard Operating Procedure

SPCC Spill Prevention, Control and Countermeasures

TCLP Toxicity Characteristic Leachate Procedure

TSCA Toxic Substances Control Act

TSDF Treatment, Storage and Disposal Facility

UCMJ Uniform Code of Military Justice

UXO Unexploded Ordnance

WMM Waste Military Munitions

CONTACT LIST

iv

Figure A

Title Phone #

Chief, Environmental Management Division 256-876-8554

Installation Compliance Branch Chief 256-876-8607

Garrison EMD Compliance, RCRA Lead

Hazardous Waste Management/ Hazardous

Materials

256-876-6123

Hazardous Waste Management/ Hazardous Materials Team

256-955-8503

256-876-6968

256-876-6332

Hazardous/Non Hazardous Waste Turn-In paper Work USARMY Redstone Arsenal USAG List DPW- HazWaste@mail.mil

Solid Waste Program 256-876-1899

Hazardous Waste Turn-In by appointment (Office Hours 0730 to 1600 hrs.)

256-876-6332

DLADS-HSV Office 256-690-5755

Garrison EMD RSA On –Scene Spill Coordinator and NPDES Compliance 256-955-8501

Fire Department

(FOR EMERGENCY, DIAL 911)

Non-Emergency

256-876-9679

Alabama Department of Environmental Management (ADEM) 1400 Coliseum Boulevard

Montgomery, Alabama 36110-2400

334-271-7700

Redstone Base Supply Alabama Institute of the Deaf and Blind (AIDB)

256-876-4011

RSA ISS Environmental Laboratory 256-876-4062

Garrison Safety Office 256-313-3297

Consolidation, Recycling, and Reuse Center (CRRC)

Building 5423 Jungerman Road 256-955-6612

OBOD Must call and delivery coordinated.

256-876-1332

AMCOM UXO Safety Officer 256-842-4253 Alt: 256-945-0293

Minor Service Order WCFS-REDSTNB-SORD@chugachgov.com 256-876-2801

SECTION ONE Introduction

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1.1 PURPOSE AND OBJECTIVE

The United States Army is committed to proper handling of the hazardous wastes that are generated on its installations. The primary objective of this document is to provide a plan that gives personnel working with hazardous waste the essential tools for effective management. The purpose of this plan is to identify and establish the requirements for the accumulation, storage, handling, and disposal of hazardous waste on Redstone

Arsenal from the point of generation to the point of disposal.

This plan was developed in accordance with Army Regulation (AR) 200-1, Environmental

Protection and Enhancement; the Alabama Department of Environmental Management

(ADEM) Administrative Code; and the Resource Conservation and Recovery Act (RCRA), as amended. In the event that any of the provisions contained in this plan are superseded or otherwise modified by changes to the Code of Federal Regulations (CFR) or the ADEM

Administrative Code, the CFR and ADEM Administrative Code will take precedence over this plan.

This document implements the requirements of AR 200-1, Chapter 10-1 and provides installation personnel with specific procedures and responsibilities to manage hazardous wastes consistent with federal, state and local laws and regulations. The Hazardous

Waste Management Plan (HWMP) serves as documentation for regulatory authorities that such a program is in place.

The HWMP documents personnel and procedures to ensure each step in the "cradle-to-grave" management of hazardous wastes is carried out in a consistent manner and in accordance with regulatory requirements. Procedures are either referenced or included in this HWMP, as necessary, to provide documented hazardous waste management instructions, from the time of waste generation until it is transported offsite for reuse or disposal.

1.2 APPLICABILITY

The HWMP is intended to be comprehensive, covering all operations involving hazardous waste, including all activities and tenants that generate or otherwise manage hazardous waste.

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The requirements of this document are applicable to all military, civilian and contract personnel at Redstone, including commanders and directors.

1.3 IMPLEMENTATION

Implementation of a comprehensive hazardous waste management program mandated by RCRA requires maximum cooperation of all activities on RSA. It is the responsibility of the Garrison Commander to ensure compliance with all RCRA requirements for Redstone and to notify and report to the Environmental Protection Agency (EPA) or ADEM, as required, for all installation activities, including tenant activities. The individual installation organizations (generating activities) are accountable for conducting their activities in accordance with this plan. Each generating organization will ensure compliance with

RCRA regulations at the facility.

1.3.1 Plan Review

This plan will be reviewed at least annually and when a process change occurs. The review will be documented in the following table A.

Date Review Completed Signature of Person Performing Review

Comments

23 May 2021

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1.3.2 Revision Log

Revisions made to the plan, including the date of the revision, the section of the plan being revised, the reason for the change, and the signature of the person making the change will be documented in the following table B.

Date of Change

Page Numbers/ Section

Signature of Person Performing Review

Reason for Change

17 Sep 21 2-6/2.5 paragraph 3 Request made to remove "365" and replace with "annually".

SECTION TWO Installation and Regulatory Overview

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2.1 GENERAL

Redstone Arsenal is a contiguous U.S. Army installation located in Madison County of north-central Alabama. It is bounded on the north by Interstate 565, on the east and northeast by the City of Huntsville, on the west and northwest by the City of Madison, and on the south by the Tennessee River. Over the past ten (10) years, the property (City of

Madison) to the west of RSA has undergone substantial commercial and residential development.

RSA is approximately 6 miles wide in an east to west direction and 10 miles long in a north to south direction. The installation occupies an approximate area of 38,100 acres.

Approximately 5,617 acres, a portion of Wheeler National Wildlife Refuge (WNWR), is located within the installation boundary and used by the Army under a 1941 permit agreement with the U.S. Department of Interior’s U.S. Fish and Wildlife Service (USFWS).

The part of the refuge on RSA encompasses portions of the Wheeler Reservoir, Indian

Creek, and Huntsville Spring Branch. The RSA Resource Conservation and Recovery

Act (RCRA)-permitted hazardous waste management units, consist of the HWSA Unit(s) managed by Army Materiel Command (CCDC), all of which are all located off Buxton

Road at the southern end of the installation. RSA began operation during the World War

II (WWII) era as an element of the Chemical Warfare Service. The majority of the land that now comprises RSA was purchased between 1941 and 1942, while the remainder of the land was used by the Army under an agreement with the Department of the Interior and land use permit granted by the Tennessee Valley Authority (TVA). Construction of the Chemical Warfare Services structures, appurtenances, and other improvements on the land began in 1941. Shortly thereafter, the Ordnance Corps began development of ordnance facilities, which, through the years, evolved into what is now known as Redstone

Arsenal. At the end of WWII, the installation was declared to be excess and advertised for sale. The sale was not successful and led to the reactivation of RSA as a rocket and missile research center. In 1950, the guided missile program stationed at Fort Bliss was transferred to RSA. As a result, in 1951, RSA’s mission became a combined effort for both the manufacture of chemical ammunitions and the national responsibility for rocket and missile research, development, and testing. The rocket and missile research conducted at RSA was instrumental in the development of modern defense systems and

2-1 the U.S. Space Program. In 1960, the George C. Marshall Space Flight Center (MSFC), an element of the National Aeronautics and Space Administration (NASA), was established within the boundaries of RSA. With the establishment of MSFC, Army rocket and missile personnel were transferred to NASA to continue development of the space program. RSA which operates under the jurisdiction of the Installation Management

Command (IMCOM), is home to a multitude (70+) of government and contractor tenants and government owned, commercially leased entities. It remains a center of excellence for research, development, testing evaluation of the Army’s missile programs.

A sampling of organizations currently residing on RSA includes but is not limited to:

• AAFES – Army and Air Force Exchange Service

• ACC – Army Contracting Command

• AMC – Army Materiel Command

• AMCOM – US Army Aviation and Missile Command

• ATF – Alcohol, Tobacco, and Firearms

• DEVCOM AvMC – Combat Capability and Development Command Ammunition and Missile Command

• DCMA – Defense Contract Management Agency

• USAG-Redstone-DPW – U.S. Army Garrison-Redstone Department Public Works

• FBI – Federal Bureau of Investigation

• MDA – Missile Defense Agency

• MSIC – Missile and Space Intelligence Center

• NASA-MSFC – National Aeronautics Space Administration – Marshall Space Flight Center

• PEO – Aviation – Program Executive Office – Aviation

• PEO - IEW&S - Program Executive Office – Intelligence, Electronic Warfare and Sensors

• PEO – M&S – Program Executive Office – Missiles and Space

• RTC – U.S. Army Redstone Test Center

• SMDC – U.S. Army Space and Missile Defense Command

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2.2 REGULATORY AUTHORITY

2.2.1 Federal Regulations

RCRA is the principal Federal legislation governing the management of solid and hazardous waste. The EPA has established regulations under RCRA which govern hazardous waste generation, storage, transportation, and disposal under Title 40 of the

CFR Parts 260 through 299.

Part 260 provides general guidance for the use of the regulations and sets forth provisions, which are applicable to all parts.

Part 261 identifies and lists various wastes considered by EPA to be hazardous.

This part establishes the criteria by which wastes are characterized as hazardous.

Part 262 establishes standards applicable to generators of hazardous waste, including requirements for reporting and manifesting of hazardous waste shipments.

Part 263 establishes standards for transporters of hazardous wastes including manifesting and recordkeeping.

Part 264 establishes standards for owners and operators of hazardous waste treatment, storage, and disposal (TSD) facilities.

Part 265 establishes interim status standards for owners and operators of hazardous waste TSD facilities. These are the standards with which existing facilities must comply if they are to remain in operation until EPA takes final action on their permit applications.

Part 268 provides land disposal restrictions (LDR).

Part 273 provides standards for Universal Waste Management.

Part 279 provides standards for the management of used oil.

2.2.2 State Regulations

On December 22, 1987, the State of Alabama was granted final authorization from the

EPA to operate its own hazardous waste management program. The authorization, however, is subject to the authority retained by EPA in accordance with the Hazardous and Solid Waste Amendments (HSWA) of 1984. Generators, transporters, and owners/operators of hazardous waste TSD facilities in Alabama are now subject to the

2-2

Alabama Hazardous Waste Management Rules in lieu of the Federal regulations adopted by the EPA.

ADEM has been designated the lead agency in developing and administering the hazardous waste management program in Alabama.

The Alabama Hazardous Waste Management Rules are contained in the ADEM

Administrative Code, Land Division - Hazardous Waste Program - Division 14. The State of Alabama has essentially adopted the Federal hazardous waste regulations. Some of

Alabama’s requirements are more stringent than the federal requirements. Any management requirements that are stricter than federal requirements are specified in the appropriate section of this plan. In Alabama, any generator (including small quantity generators who are partially exempt under RCRA) may be required to obtain approval before transporting, treating, or disposing of certain types of hazardous waste. The following sections are included in the ADEM Administrative Code:

Chapter 335-14-1 - Hazardous Waste Management System: General

Chapter 335-14-2 - Identification and Listing of Hazardous Waste

Chapter 335-14-3 - Standards Applicable to Generators of Hazardous Waste

Chapter 335-14-4 - Standards Applicable to Transporters of Hazardous Waste

Chapter 335-14-5 - Standards for Owners and Operators of Hazardous Waste

Treatment, Storage and Disposal Facilities

Chapter 335-14-6 - Interim Status Standards for Owners and Operators of

Hazardous Waste Treatment, Storage and Disposal Facilities

Chapter 335-14-7 - Standards for the Management of Specific Hazardous Wastes and Specific Types of Hazardous Waste Management Facilities

Chapter 335-14-8 - Permit Program

Chapter 335-14-9 - Land Disposal Restrictions

Chapter 335-14-11 - Standards for Universal Waste Management

Chapter 335-14-17 - Standards for the Management of Used Oil

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2.2.3 Army Regulations

The Army is committed to environmental stewardship in all actions as an integral part of the Army mission. Department of Defense (DOD) installations and personnel are required to comply with all federal, state, and local laws, as well as Army requirements, designed to protect human health and the environment. Pursuant to this requirement, the

Department of the Army (DA) has developed AR 200-1, Environmental Protection and

Enhancement, which prescribes responsibilities, policies, and procedures to preserve, protect, and restore the quality of the environment. This regulation is to be implemented in a number of areas, including hazardous waste management. The procedures in

Chapter 10 of AR 200-1 incorporate all applicable regulatory requirements for hazardous waste management, and specify implementation of local procedures and responsibilities for execution of the hazardous waste management program. Chapter 10, Waste

Management, further defines the policy for managing hazardous and solid wastes.

Related policy guidance on solid waste may be found in the Redstone Arsenal Integrated

Solid Waste Management Plan, May 2016. Specifically, Redstone Arsenal should ensure that waste accumulation, storage, or transfer facilities are designed and constructed to prevent releases to the environment.

This document includes the elements of a HWMP required by AR 200-1:

Chapter 10-1.d.(3) Develop and implement a hazardous waste management plan

(HWMP) or other comparable document appropriate to the size and complexity of the operation. The HWMP (or other comparable document) should include, at a minimum, written procedures for all aspects of hazardous waste management, to include the identification, storage, and transporting of HW; training of personnel; tracking manifests; and maintaining required records.

2.2.4 Redstone Arsenal Policy

It is an installation policy that any command, activity, tenant, organization, or contractor at Redstone Arsenal that generates or otherwise manages hazardous waste, is subject to and shall comply with all applicable federal, state, local, Army and installation requirements. The Directorate of Public Works, Environmental Management Division

2-4

(RSA Garrison-EMD) is responsible for administering the Redstone Arsenal HWMP.

Any entity found to be in violation of the provisions of any of these requirements may be subject to appropriate environmental agency fines and penalties. In the absence of appropriate regulatory guidelines, hazardous waste shall be managed in a manner that minimizes adverse effects to human health and the environment.

2.2.5 Waste Minimization

Potential hazardous wastes will be recycled and reused to the maximum extent practicable at Redstone Arsenal. Hazardous wastes, which are not economically recoverable, shall be disposed in a way that will prevent or minimize pollution of the environment and in compliance with federal, state, and local hazardous waste regulations.

Emphasis will be placed on source reduction and materials substitution methods as followed in Redstone Arsenal Garrison Hazardous Waste Minimization Plan 200-8.

All activities at Redstone are responsible for seeking the reduction and elimination of hazardous chemicals/hazardous wastes in their respective organizations and pursuing the use of non-hazardous chemicals.

Organization HAZMAT EPOCs shall identify safer & healthier business practices and

Pollution Prevention (P2) options such as elimination, process modification, substitution, reuse/reissue and/or recycling before the material is even placed on order. All inventory material authorization requests should be reviewed by the organization’s EPOC prior to purchasing.

2.3 EPA IDENTIFICATION (ID) NUMBER

Redstone Arsenal is a large quantity generator (e.g. greater than 1,000 Kg per month) of hazardous waste. The RSA EPA identification (ID) number for generating hazardous waste is AL7210020742 with permitted HWSU (hazardous waste storage units) managed by the U.S. Army Garrison DWP-EMD, OBOD Unit managed by DEVCOM-AvMC, and

Explosive Destruction System Unit(s) managed by AMC.

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2.4 HAZARDOUS WASTE STORAGE UNITS (HWSU)

Currently, RSA has 33 permitted <1 year treatment storage and disposal facilities, and 14

<90-day Hazardous Waste Storage Units (<90 day HWSU). If operational conditions require closure of one of the <90 day-HWSU, it will be closed in accordance with ADEM

Administrative Code Chapter 335-14-3-.03(5)(a)5. This section requires compliance with the closure requirements of 335-14-3-.03 and the applicable requirements of 335-14-6-

.09(9), 335-14-6-.10(8), 335-14-6-.23(6), and 335-14-6-.30(3), and the record keeping requirements of rules 335-14-3-.04(1)(c) and 335-14-3-.04(4).

The <90 day HWSUs and <1 year HWSUs are listed on Figure B-1.

Additionally, Redstone Arsenal operates Hazardous Waste Part B Permitted <1 year

HWSUs. RSA manages these HWSUs with the same practices as at a <90 day HWSUs.

Any references to requirements for a <90 day HWSUs are also applicable to the accumulation site at the <1 year HWSUs.

2-5

Figure B

Hazardous Waste Storage Units

CARA- Analytical and Remediation Activity

Hazardous waste storage units <1 year - 8205, 8208, 8209, 8210, 8211, 8212, 8213, 8214, 8216, 8217, 8218, 8219, 8220, 8221, 8222, 8223, 8224, 8225, 8226, 8227, 8228, 8229, 8230 and 8231.

DEVCOM AvMC

<90 day storage units – Buildings: 5421, 5477, 7172, 7173, 7371A, 7371C, 7631, 7815 and 8408

Federal Bureau of Investigation

<90 day storage unit – Buildings: 4940

USAG-Redstone DPW-EMD -

Hazardous waste storage units <1 year – 8621, 8622, 8623, 8624, 8625, 8630, 8631, 8632 and 8633

IR- Installation Restoration; APTIM Federal Services

<90 day storage unit – Buildings: 7700

LRC

<90 day storage unit - Buildings: 3633

MDA

<90 day storage unit – Buildings: 7319

Contractor Support for Redstone Arsenal

<90 day storage unit – Buildings: 5423

2-6

2.5 GENERAL HAZARDOUS WASTE TRAINING REQUIREMENTS

This section provides general information related to the level of training required by all personnel who manage or supervise hazardous waste activities or handle hazardous waste in the course of their employment duties. The training shall be implemented by all

Redstone Arsenal installation and tenant activities.

Federal and state regulations require that all personnel managing or handling hazardous waste must be trained, either through classroom instruction or on-the-job-training, to respond to emergencies, protect the environment, and properly handle and dispose of hazardous wastes. The regulatory requirements for training may be found in ADEM, Division 14, 335-14-5-.02(7).

Facility personnel whose duties have a direct effect on hazardous waste management and/or hazardous waste accumulation, whether by direct contact with the hazardous waste or through hazardous waste management activities, must receive training. Each person managing or handling hazardous waste must receive introductory and annual update hazardous waste training corresponding with his/her responsibilities. Training must be completed annually.

The introductory training must be completed within 6 months of the date on which the employee begins work in a position requiring such training. Employees must be immediately and continuously supervised when performing hazardous waste duties until such training is completed.

At a minimum, all supervisors and managers of hazardous waste activities will be trained in installation-sponsored or off-site training courses that meet the established training requirements of this plan. It is their responsibility to ensure that personnel working for them are trained either in formal courses or in-house using on-the-job-training and "shop level" training classes to meet the regulatory requirements.

Each organization will develop a program to train its hazardous waste handlers, using an appropriate combination of the following:

Installation-sponsored through RSA Garrison-EMD (Trainer is certified through ADEM compliant Training) hazardous waste yearly training courses consist of:

o Hazardous Waste Management- RCRA o Hazardous Material HAZCOM o Waste Turn-In procedure

On Site or off site HAZCOM/HAZWOPER.

Off-site hazardous waste-RCRA training courses

Organization level training such as shop talks, lectures, and guest lectures

Reading and discussing installation and organization level hazardous waste management plans, SOPs, and spill contingency plans

On-the-job instruction in hazardous waste management procedures from a person trained in those procedures

Performance of hazardous waste management procedures under the direct supervision of a person trained in those procedures

Personnel responsible for shipping hazardous waste and signing hazardous waste manifests must be trained in accordance with Department of Transportation (DOT) 49

CFR 172, Subpart H, which requires initial and recurrent training. Only personnel within

RSA Garrison-EMD designated by the Garrison Commander are authorized to sign manifests.

All instances of training must be documented using Figure C-1, Hazardous Waste Job

Description and Training Record. The training record must include:

Name of Employee

Job Title

Job Description

A written description of the type and amount of both introductory and continued training that will be given to each person filling a position.

Records that document that the training required has been given to, and completed by, facility personnel.

A training record must be maintained on-site for every current person in the organization handling hazardous waste. Training must be kept for the duration of employment and then three years after an employee leaves their waste management position at the organization.

Figure C Job Description Form

HAZARDOUS WASTE MANAGEMENT

****** JOB DESCRIPTION FORM AND TRAINING REQUIREMENTS *****

Under penalty of federal and state laws, job descriptions and training documentation relating to hazardous waste management must be kept on file for all employees on Redstone Arsenal that collect, process, treat, dispose, recover, transport, or store hazardous waste.

The law further requires that all training records (relating to hazardous waste management) on current personnel must be kept indefinitely and all training records on former personnel must be kept at least three years from the date the employee last worked in that position. The following form is provided to assist in compliance with the above stated laws. Location of filing for this form is at the discretion of the waste generator but must be readily available for inspections by the Alabama Department of Environmental Management (ADEM), Environmental Protection Agency (EPA), and Directorate of Public Works (DPW).

NAME: UNIT:

JOB TITLE: Hire Date: _______________ End Date:______________

JOB DESCRIPTION (As related to hazardous waste management only)

Employee’s job position relating to hazardous waste management includes: Handling/disposing/storing/ transporting POL and hazardous waste generated by one or more of the following: (check applicable portions below):

Motor Pool Maintenance Laboratory waste, Radioactive and Biological waste Adhesives, Sealants, Paints and Thinners Photographic Developing Laboratories or Printing Facilities Use of Cleaning Solvents All aerosol cans Acetone Pesticides, Insecticides, Rodenticides, Herbicides, Fungicides Used and unused florescent lamps Compressed Gas Cylinders (empty, full, or partially filled)

Batteries (including Lithium, Magnesium, Mercury, Nickel-Cadmium, & Lead Acid)

Other: All other Waste on the Installation.

TRAINING (As related to hazardous waste management only)

Employees must receive hazardous waste management training within 6 months of assumption of his/her duties as it relates to hazardous waste management. Employees may not work hazardous waste management duties unsupervised until completion of training. A person trained in hazardous waste management procedures who has attended the Public Works Business Center’s Environmental Compliance Training or ADEM accepted equivalent training must conduct this training. All Employees trained must complete an annual review of the initial training. Training of affected Employees must include the following is applicable:

HAZARDOUS WASTE/CONTROLLED MATERIALS EMERGENCY SPILL RESPONSE PROCEDURES

Instruction on proper disposal and storage of Hazardous and Universal Waste and USED oil.

Location of emergency equipment such as eyewashes and shower points

Record keeping requirements-training and job descriptions Site Specific Contingency Plan with evacuation routes Manifesting requirements Emergency Notification Procedures

Perform weekly inspections of HW container storage areas and keep HW weekly inspection log up-to-date, signed, dated and marked with time of inspections.

Emergency Cutoff Procedures

Process Hazardous Waste documentation for turn-in

Spill Absorbents

Ensure hazardous waste accumulation start dates are within acceptable timeframe.

HAZARDOUS MATERIAL (HAZMAT)

Hazardous Waste Turn In Process

SAFETY DATA SHEETS (SDS)

TYPE TRAINING DATE TRAINED BY TRAINEE SIGNATURE

Initial Training

Annual Refresher

Annual Refresher

Annual Refresher

SECTION THREE Responsibilities

3-1

3.1 GENERAL

Environmental compliance is both a command and an individual responsibility.

Commanders and heads of activities at all levels on and around Redstone Arsenal are responsible for compliance with this HWMP. Responsibilities for implementing this plan are distributed throughout installation organizations that generate, accumulate, transport, turn-in, monitor, or respond to incidents involving hazardous waste. Overall compliance with federal, state, and local hazardous waste laws and Army regulations is the responsibility of the Installation Commander through the Environmental Management

System (EMS). This section specifies the responsibilities of all installation activities and personnel (military, civilian, and contractors) in generating and accumulating hazardous waste.

3.2 GARRISON COMMANDER

a. Ensures that RSA is compliant with all applicable environmental laws and regulations.

b. Programs and budgets for the necessary funds and personnel in order to execute a hazardous waste program and comply with applicable state, federal, and Army regulations.

c. Serves as the chairperson of the EQCC which meets quarterly to discuss and oversee pertinent environmental issues.

d. Signs RCRA permit applications, compliance agreements, consent orders, and responses to Notices of Violation (NOV) with the state and federal regulatory officials, following review by the installation Staff Judge Advocate (SJA) and the

RSA Garrison-EMD.

e. Establishes an organizational structure to plan, execute and monitor hazardous waste programs and waste minimization initiatives.

f. Delegates the preparation and signature of all shipping manifests required by federal and state law for wastes to appropriately trained personnel within RSA

Garrison-EMD.

3-2

3.3 ENVIRONMENTAL QUALITY CONTROL COMMITTEE (EQCC)

a. Provides the Garrison Commander with a regularly scheduled status report on environmental issues and actions, including those involving hazardous wastes and materials.

b. Provides a forum for dissemination of information and a forum for the principal parties responsible for environmental and occupational health to introduce and resolve environmental issues.

c. Increases the awareness and active participation at all organizational levels in meeting all regulatory requirements.

d. Ensures that management of hazardous waste on the installation complies with applicable portions of ADEM Administrative Code Division 14 and 40 CFR Parts

260-279.

e. Ensures all enforcement actions are resolved quickly.

3.4 Chief, EMD (AMIM-REP-E):

a. Overall management of hazardous waste and central coordination of the waste management program at RSA.

b. Assist with the disposal of HW which fail to meet the handling criterion of DLA- DS and do not lend itself to recycling or reuse.

c. Perform or coordinate surveys of hazardous material handling activities and hazardous waste generation sites. These surveys will evaluate waste management requirements for corrective action where necessary.

d. Maintain records and serves as the point of contact with all federal, state, and ensuring compliance with the laws, procedures, and regulations governing hazardous waste by the activities and tenants of RSA.

e. Provide guidance to assist generators in obtaining the analysis of hazardous waste and suspected hazardous waste.

f. Notify the Commander, Fox Army Medical Center, of any hazardous waste incident involving personnel exposure.

g. Serve as a member of the EQCC, as well as advisor and point of contact of procedural and technical matters for the EQCC.

3-3

3.5 UNIT COMMANDERS, DIRECTORS, AND SUPERVISORS (GOVERNMENT

FACILITIES AND CONTRACTORS)

The commander/director of each major subordinate command, brigade, battalion, directorate, tenant organization, and civilian contractor that handles hazardous materials/waste will:

a. Appoint in writing personnel, civilian or contractor supervisors as Environmental

Officers (EO) to RSA Garrison-EMD.

b. Submit in writing personnel, civilian or contactor supervisors overseeing 90-

HWSUs and HWSAA within their area of responsibility that generate, manage, accumulate, store, and or transport hazardous waste.

c. Set organization-level hazardous waste management policy and establish an active hazardous waste management program in compliance with all pertinent laws and regulations and the Redstone Arsenal HWMP.

d. Ensure waste profile information changes (e.g. change in chemicals used, change in safety data sheets [SDS], etc.) are communicated to RSA Garrison-EMD prior to waste accumulation.

e. Ensure that all Environmental Officers and Hazardous Waste Managers and handlers are trained in accordance with this HWMP.

f. Ensure that all personnel who may be exposed to hazardous waste in the course of their work are made aware of the hazards to which they are exposed as well as the precautions required to protect both the environment and themselves in operational areas.

g. Ensure that materials and supplies, including the necessary and proper fitting of personal protective equipment (PPE) and emergency response supplies, are provided for the proper management and handling of hazardous waste.

h. Ensure that newly assigned personnel do not work in unsupervised positions until they have completed the initial training program. Further, they ensure that all hazardous waste handlers complete the required refresher training on an annual basis.

i. Become familiar with the installation hazardous waste minimization goals.

3-4

j. Units, tenants, and activities generating hazardous waste are responsible for estimating annual hazardous waste disposal costs and including in budget forecast.

3.6 ENVIRONMENTAL OFFICERS

a. Identify all hazardous waste within areas of responsibility. Identify the location of all HWSAA and <90 day HWSUs within their organization, and submit an updated list to RSA Garrison-EMD at least annually. Notification of new SAAs with MFR.

b. Provide written notification to the RSA Garrison-EMD Hazardous Waste Program

Manager if any changes to waste streams or accumulation areas occur between list submissions. Any proposed change, including adding or removing accumulation areas or waste streams, should be coordinated with DPW-EMD prior to implementation.

c. Prepare a Contingency Quick Reference Guide (Figure D) for the storage and management of hazardous waste for each HWSAA, <1 year HWSU and <90 day

HWSU.

d. Ensure that all hazardous waste handlers obtain the initial mandatory training program within 60 days, and complete the initial training program within 6 months of the date of their employment in or assignment to the waste handling position.

e. Ensure that the training records are maintained IAW Section 2.5 in this plan.

f. Ensure that all hazardous waste is placed in a RSA Garrison-EMD approved

HWSAA.

g. Ensure the appropriate information and warning signs are posted at each HWSAA.

HWSAA signs should include the following information: Hazardous Waste Satellite

Accumulation Area with # ID, HWSAA POC name and his/her telephone number, along with the Alternate HWSAA POC name and telephone number.