TE 04 Fort Bliss Hazardous Waste Management Plan.pdf

HAZARDOUS WASTE

MANAGEMENT PLAN

FORT BLISS GARRISON COMMAND

FORT BLISS, TEXAS

Home of the First Armored Division

January 2017

HAZARDOUS WASTE MANAGEMENT PLAN

TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY

SECTION 1 INTRODUCTION

1.1 PURPOSE

1.2 APPLICABLE REGULATIONS

1.3 POLICY

1.4 HAZARDOUS WASTE MANAGEMENT RESPONSIBILITIES

1.4.1 Garrison Commander

1.4.2 Office of the Staff Judge Advocate

1.4.3 DPW-Environmental Division

1.4.4 Defense Logistics Agency (DLA), Fort Bliss

1.4.5 Commands, Directorates, and Other Activities Supported by the Garrison Command ... 3

1.4.6 Tenants and Other Activities Not Part of the Garrison Command

1.4.7 Preventive Medicine Services, WBAMC

1.4.8 Directorate of Emergency Services, Fire Department

1.4.9 Directorate of Contracting

SECTION 2 IDENTIFICATION OF HAZARDOUS WASTE

2.1 DEFINITION OF WASTE

2.2 HAZARDOUS WASTES

2.2.1 Listed Hazardous Wastes

2.2.2 Characteristic Hazardous Wastes

2.3 ACUTELY HAZARDOUS WASTES

2.4 EXEMPT WASTES

2.5 NON-RCRA REGULATED WASTES

2.6 HAZARDOUS MATERIALS (HM)

2.7 PETROLEUM, OIL, AND LUBRICANT (POL) PRODUCTS

2.8 POLYCHLORINATED BIPHENYLS (PCBs)

2.9 SPECIAL WASTES

SECTION 3 HAZARDOUS WASTE MANAGEMENT PROCEDURES

3.1 GENERAL

3.2 HAZARDOUS WASTE MANAGEMENT LOCATIONS

3.3 MANAGEMENT OF SATELLITE ACCUMULATION POINTS (SAPs)

3.4 MANAGEMENT OF 90-DAY STORAGE FACILITIES

3.4.1 Container Storage Area Requirements

3.4.2 Incompatible Waste Storage

3.5 HAZARDOUS WASTE STORAGE FACILITY OPERATIONS

3.5.1 HW Storage Facility Information

3.5.2 Responsibilities

3.6 HW TRANSPORTATION REQUIREMENTS

3.7 RECORDKEEPING AND REPORTING REQUIREMENTS

SECTION 4 TRAINING REQUIREMENTS

4.1 GENERAL

4.2 TRAINING RESPONSIBILITIES

4.2.1 DPW-Environmental Division

4.2.2 Generators

4.2.3 Installation Safety Office

4.3 TRAINING STANDARDS

4.3.1 Hazard Communication Standard (HAZCOM)

4.3.2 Respiratory Protection

4.3.3 Hazardous Material Waste Clean-up; Spill Response

4.3.4 Hazardous Waste Transportation

SECTION 5 FREQUENTLY ASKED QUESTIONS

LIST OF TABLES

1-1 Point of Contacts……………………………………………………………………………

2-1 Examples of Waste

2-2 Categories of Listed Waste

2-3 Characteristics of Hazardous Waste

2-4 Maximum Concentration of Contaminants for Toxicity Characteristic

2-5 Classifications of Waste………

3-1 Satellite Accumulation Point Requirements

3-2 90-Day Storage Facility Requirements

3-3 Waste Inventory Log for 90-Day Storage Facilities

3-4 Hazardous Materials/Hazardous Waste Storage Incompatibility Chart

3-5 Hazardous Waste Storage Facility Information

3-6 Report Submission Requirements

3-7 Record Keeping Requirements

4-1 Training Requirements for Hazardous Waste Handlers and Transporters

APPENDICES

APPENDIX A Satellite Accumulation Point Operating Procedure

LIST OF FIGURES

3-1 Schematic of Waste Flow

3-2 USEPA Hazardous Waste Label

3-3 Non-Hazardous Waste Label

3-4 DOT Shipping Labels

3-5 Example of Form 1348-1A

3-6 Hazardous Waste Profile Sheet

3-7 Example of EPA Hazardous Waste Manifest

EXECUTIVE SUMMARY

HAZARDOUS WASTE MANAGEMENT PLAN

The Hazardous Waste Management Plan (HWMP) is prepared in accordance with the requirements of Army Regulation 200-1. The purpose of the plan is to ensure management of wastes in a safe and environmentally sound manner. The plan provides guidance to Commands, Tenants, Contractors, and all other activities supported by Fort Bliss on issues related to hazardous and non-hazardous waste management. In addition, the plan helps waste generators at Fort Bliss to:

Protect the environment Maintain compliance with regulations Reduce hazardous waste generation and associated disposal costs

Minimize spills and resulting cleanup/disposal costs

Minimize/eliminate regulatory penalties.

The HWMP delineates Army policy on the management of hazardous wastes. While the Garrison Commander is responsible for overall management of hazardous wastes, specific responsibilities are delegated in accordance with Army policy. The responsibilities for various Commands/Directorates at Fort Bliss are established by the HWMP. In addition the plan:

Explains Federal, State, Army, and local regulations applicable to the management of wastes at Fort Bliss.

Provides guidance on the identification and classification of wastes in accordance with regulations. Information presented in this plan allows generators to distinguish between hazardous and non-hazardous wastes; petroleum, oil, and lubricant (POL) products; and hazardous materials.

Establishes Fort Bliss procedures for management of hazardous wastes. These include:

Specific responsibilities for organizations that generate or manage hazardous wastes.

Procedures for handling wastes at the point of generation and requirements for Satellite Accumulation Points (SAPs).

Procedures for turning wastes in to the HWFS at the storage facility, Building 11614, East Fort Bliss.

Training requirements for personnel at Satellite Accumulation Points and the <90 day storage facility.

Operating procedures for the <90 day storage facility.

This plan provides guidance and procedures for a broad range of issues, it is recognized that specific issues may have to be handled on an individual basis. The plan includes contact numbers for the DPW- Environmental Division and other organizations that can address specific situations

SECTION 1 INTRODUCTION

1.1 PURPOSE

The purpose of the Fort Bliss Hazardous Waste Management Plan (HWMP) is to ensure management of hazardous wastes in a compliant, safe and environmentally sound manner.

1.2 APPLICABLE REGULATIONS

Management of hazardous wastes at Fort Bliss is governed by Federal, State, and Army Regulations.

Applicable Federal legislation is listed below:

Subtitle C of the Solid Waste Disposal Act as amended by the Resource Conservation and Recovery Act of 1976 (RCRA) and the Hazardous and Solid Waste Amendments of

1984 (HSWA).

The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) and the Superfund Amendment and Reauthorization Act of 1986 (SARA).

Title 40 Code of Federal Regulations (CFR), Parts 260 to 279.

Army Regulation 200-1, Environmental Protection and Enhancement, 13 Dec 2007.

Texas Administrative Code (TAC), Title 30 - Environmental Quality, Part 1, Texas Commission on Environmental Quality (TCEQ), Chapter 335 - Industrial Solid Waste and Municipal Hazardous Waste Management.

New Mexico Administrative Code (NMAC), Title 20-Environmental Protection, Chapter 4 - Hazardous Waste, June 14, 2000.

1.3 POLICY

In accordance with the objectives of AR 200-1, the management of hazardous waste includes the following:

Ensure that all hazardous waste management activities are conducted in compliance with federal, state, and local regulations.

Delegate responsibilities, establish standards and procedures for the safe, efficient, and economical collection, recycling, and disposal of hazardous waste in an environmentally acceptable manner

Assure waste management practices (for generation, treatment, storage, disposal, and transportation) that will protect public health and the environment.

Reduce the need for corrective action through controlled management of solid waste and hazardous waste

Implement a Pollution Prevention (P2) Plan (separate document) to reduce the volume and/or toxicity of HW in the most practical and economical manner and to minimize present/future threats to human health and the environment caused by the treatment, storage or disposal of HW Develop and implement emergency response procedures and spill contingency plans to minimize hazards from fires, explosions, or any release of HW to air, soil or water. These procedures spelled out on the Installation Spill Prevention and Contingency Plan (ISCP).

1.4 HAZARDOUS WASTE MANAGEMENT RESPONSIBILITIES

The Garrison Commander has overall responsibility for environmental compliance and management of hazardous waste. However, coordination and implementation of the hazardous waste management system are delegated to various organizations at Fort Bliss. Responsibilities of these organizations are defined in this section of the Plan.

1.4.1 Garrison Commander

Ensure installation complies with applicable Federal, State, and local environmental laws, regulations, internal directives, goals and Executive Orders.

Signs the RCRA delegation of Authority to sign Manifests.

Designate personnel who are responsible and accountable for executing major program requirements as prescribed in AR 200-1.

All contracts for hazardous waste disposal must be reviewed by DPW-E, Directorate of Contracting and approved by the Garrison Commander.

1.4.2 Office of the Staff Judge Advocate

Provides guidance and legal opinions on interpreting federal, state, and local laws and regulations governing hazardous wastes.

1.4.3 DPW-Environmental Division

Acts as the Garrison Commander's representative for the management of HW

Is considered as the “generator” for funding purposes of orphan wastes.

Comply with all applicable Federal, State, and local HW regulations.

Effectively managed and reduce its generations.

Minimize HW generation through pollution prevention actions.

Systematically evaluate waste streams to ensure all potential hazardous or special wastes are properly identified and characterize.. Ensure that all persons handling or managing HW are provided appropriate training..

Maintain appropriate records in accordance with RCRA and applicable State requirement.

Develop and implement a HW Management Plan.

Ensure HW manifests are only signed by those individuals who have been appropriately trained and are authorized in writing by the GC.

Conduct yearly HW inventory and maintain installation HW inventory in accordance with regulations.

Provide technical assistance to generators.

Assist generators in minimizing or eliminating HW/HM through substitution with less hazardous or non-hazardous substances.

Coordinate clean-up procedures following an accidental spill.

Maintain current HW inventories for all units.

Ensure newly assigned or attached units provide an initial report of HW.

Prepare and submit the Annual Waste Shipment Summary Reports to TCEQ. The report is a summary of all manifested items disposed of prior to December 31 of the preceding year.

Prepare and submit the Annual Site Activity Report to the TCEQ.

Consolidate and maintain all records required for the HW management program in compliance with RCRA for EPA or state inspections. These records include:

o Inspection reports for the SAPs, 90-day areas and Building 11614 o Documentation of corrective action o Supporting documentation for waste classification o Personnel training records o Conduct periodic inspections of units to ensure compliance with the HWMP.

o Report spills to regulatory agencies.

o Waste Minimization Activities for Biennial Report

Use the Defense Logistics Agency (DLA) for HW disposal with the following exceptions;

o When DLA has indicated or demonstrated the inability to provide the service o Hazardous waste generated incidental to the execution of service or construction contracts should be disposed by the contractor performing the basic contract at the contractor’s expense, using the installation generator identification number.

1.4.4 Defense Logistics Agency (DLA), Fort Bliss

Under the provisions of Department of Defense (DoD) 4160.21-M, accepts responsibility for disposal of HW generated at Fort Bliss when the waste is properly identified, contained, and labeled in accordance with Department of Transportation (DOT) and U.S.

Environmental Protection Agency (EPA) requirements.

Initiates contractual agreements for safe and legal transportation and disposal of HW.

Prepares appropriate hazardous waste manifest documentation in accordance with the DOT, TCEQ, and EPA requirements for transportation and disposal, respectively.

Maintains transportation and disposal records for all manifested HW.

Provides DPW-E with copies of waste shipment manifests for preparation of TCEQ monthly and annual HW reports.

1.4.5 Commands, Directorates, and Other Activities Supported by the Garrison Command

These activities will:

Comply with installation policies, applicable Federal, State, and local environmental laws, regulations, and EOs.

Be responsible for payment of fines resulting from noncompliance.

Ensure that all hazardous wastes generated during operations are identified.

Be responsible for analytical costs incurred to identify wastes.

Be responsible for their portion of contract costs for the Hazardous Waste Field Services (HWFS) program.

Provide DPW-E with a list of HW generated and update the list when new waste streams are generated.

Provide DPW-E with a list of all satellite accumulation points operated by the generator.

Track wastes through the process stream from generation to turn-in.

Properly package, mark, store, and make arrangements for waste to be transported to the <90 day Storage Facility (B-11614).

Ensure that all personnel handling HW are fully aware of the HW management requirements that pertain to their particular activity.

Maintain training records accessible to EPA, state inspectors, and Army inspectors.

Coordinate with the DPW-E HWFS for waste turn-in. (As soon as a container is 80% full, contact the DPW-E HWFS to arrange for pick-up.)

Maintain Satellite Accumulation Points (SAPs) in accordance with the SAP SOP.

Ensure that containers used are in good condition.

Keep HW containers segregated from non-waste materials and stored, according to waste type, in the organization's SAPs.

Immediately report spills to the Fort Bliss Fire Department.

Provide a DODAAC for reimbursable waste management costs

1.4.6 Tenants and Other Activities Not Part of the Garrison Command

These activities will:

Comply with installation policies, applicable Federal, State, and local environmental laws, regulations, and EOs and current ISSA, MOU or MOA.

Be responsible for payment of fines resulting from noncompliance.

Ensure that all hazardous wastes generated during operations are identified.

Be responsible for analytical costs incurred to identify wastes.

Be responsible for their portion of contract costs for the HWFS program.

Provide DPW-E with a list of HW generated and update the list when new waste streams are generated.

Provide DPW-E with a list of all satellite accumulation points operated by the generator.

Track wastes through the process stream from generation to turn-in.

Properly package, mark, store, and make arrangements for waste to be transported to the <90 day Storage Facility (B-11614).

Ensure that all personnel handling HW are fully aware of the HW management requirements that pertain to their particular activity.

Maintain training records accessible to EPA, state inspectors, and Army inspectors.

Coordinate with the DPW-E HWFS for waste turn-in. (As soon as a container is 80% full, contact the DPW-E HWFS to arrange for pick-up.)

Maintain Satellite Accumulation Points (SAPs) in accordance with the SAP SOP.

Ensure that containers used are in good condition.

Keep HW containers segregated from non-waste materials and stored, according to waste type, in the organization's SAPs.

Immediately report spills to the Fort Bliss Fire Department.

Provide a DODAAC for reimbursable waste management costs

1.4.7 Preventive Medicine Services, WBAMC

Comply with applicable Federal, State, and local environmental laws, regulations, and EOs.

Manage and dispose of medical, dental, veterinary, pharmaceutical and regulated medical wastes in accordance with AR 40-5 and applicable regulations.

Advise on health aspects of the installation environmental program and provide technical consultation and support services.

1.4.8 Directorate of Emergency Services, Fire Department

Provide Emergency Response Services for Hazardous Materials (HAZMAT) and Chemical, Biological, Radiological, Nuclear, and High Explosive (CBRNE)

1.4.9 Directorate of Contracting

Reviews contract for the disposal of hazardous waste and ensure contracts comply with DOD 41620.21-M.

Prepares, executes and administers all contracts for remedial activities resulting from releases of hazardous substances to the environment.

This is an UNCONTROLLED DOCUMENT when printed.06/30/20. The current document is on-line at https://imcom.bliss.army.mil/DPWE/ems/default.aspx. P a g e | 6

SECTION 2 IDENTIFICATION OF HAZARDOUS WASTE

The first step in successful waste management is the proper identification of the waste. RCRA regulations governing the management of HW are contained in 40 CFR, Parts 260 and 279.

Specifically, identification and listing of HW are contained in 40 CFR 261. This section of the HW Management Plan discusses the procedures for identification of wastes in accordance with RCRA regulations.

2.1 DEFINITION OF WASTE

A waste is any discarded material. Discarded materials that are considered waste can be solid, semi-solid, liquid, or gaseous in nature. Even a raw material or product can become a waste if it is discarded. Examples of waste are listed in Table 2-1.

TABLE 2-1 EXAMPLES OF WASTE

Waste Examples Garbage Office and household non-recyclable refuse Sludge Solids suspended in a liquid

Contaminated Soil Man-made chemicals or other alteration in the natural soil environment Liquids Used Oil, lubricants, antifreeze, cleaning supplies

2.2 HAZARDOUS WASTES

For a waste to be classified as hazardous, it must meet EPA's definition of solid waste (as specified by 40 CFR 261.20). According to this definition, a solid waste is any discarded material that is abandoned, recycled or considered inherently waste-like. Based on this definition, a solid waste could be a liquid, solid, contained gas, or sludge. Once a waste meets the definition of solid waste, it can be classified as hazardous for two reasons:

The waste is a listed hazardous waste.

The waste is a characteristic hazardous waste.

2.2.1 Listed Hazardous Wastes

EPA has identified a number of wastes as hazardous. These wastes, listed in 40 CFR 261, fall into three categories:

TABLE 2-2 CATAGORIES OF LISTED WASTE

Listed Waste Type

Source Example

F From nonspecific sources Spent solvents, such as trichloroethane, methyl ethyl ketone (MEK), xylene, and toluene

K From specific industrial processes in industries

Petroleum refining, wood preservation

P + U Discarded commercial products that have not been used in any other process

Acetone, toluene, and chromium compounds

Note: None of the waste generated at Fort Bliss falls under K listed wastes.

2.2.2 Characteristic Hazardous Wastes

Wastes that exhibit the following characteristics are classified as hazardous: Ignitable, Corrosive, Reactive, and/or Toxic. A summary of criteria for classification of characteristic hazardous waste is presented in Table 2-3.

Waste generated at Fort Bliss which may be, but is not always, characteristic hazardous wastes include chemical protective masks (containing chromium), used oil (containing lead and other metals), battery acid (lead), soil contaminated with mogas (benzene), Chemical Agent Resistant Paint (CARC) (chromium), and other paint residues (containing metals and/or organic chemicals.).

TABLE 2-3

CHARACTERISTICS OF HAZARDOUS WASTE

Type of Hazardous

Waste

EPA

Waste Code

Characteristic Examples

Ignitable D001

Liquid with a flash point less than 140o F Solid capable of causing fire through friction, absorption of moisture, or spontaneous chemical changes; when ignited, burns so vigorously and persistently that it creates a hazard.

An ignitable compressed gas as defined in 49 CFR 173.300 An oxidizer as defined in 49 CFR 173.151

Mogas; paint thinners/solvents such as MEK, toluene, xylene

Corrosive D002 Liquid or solid that corrodes steel at a rate >0.25 inches/year

Battery acid

Reactive D003

Unstable and undergo violent change without detonation React violently with water and form explosive mixtures with water Generate toxic fumes and gases when mixed with water Cyanide and sulphur bearing waste

Lithium batteries, explosives, cyanides

Toxic D004 to

D043

A solid waste is characterized as a toxic waste if it leaches certain constituents above a specified regulatory level. The waste is subjected to a procedure known as the Toxicity Characteristic Leaching Procedure (TCLP).

The waste extract is analyzed and the results compared to regulatory limits for 40 chemicals listed in Table 2-4. The waste is toxic if extract contains one of 40 toxic substances above allowable leachable level

Paints with lead or chromium, biomask filters, mercury, pesticides

TABLE 2-4

MAXIMUM CONCENTRATION OF CONTAMINANTS FOR TOXICITY

CHARACTERISTIC

EPA HW NO1 CONTAMINANT CAS NO2 REGULATORY

LEVEL (mg/L)

D004 Arsenic 7440-38-2 5.0 D005 Barium 7440-39-3 100.0 D018 Benzene 71-43-2 0.5 D006 Cadmium 7440-43-9 1.0 D019 Carbon tetrachloride 56-23-5 0.5 D020 Chlordane 57-74-9 0.03 D021 Chlorobenzene 108-90-7 100.0 D022 Chloroform 67-66-3 6.0 D007 Chromium 7440-47-3 5.0 D023 o-Cresol 95-48-7 200.03

D024 m-Cresol 108-39-4 200.03

D025 p-Cresol 106-44-5 200.03

D026 Cresol 200.03

D016 2,4-D 94-75-7 10.0 D027 1,4-Dichlorobenzene 106-46-7 7.5 D028 1,2-Dichloroethane 107-06-2 0.5 D029 I,I-Dichloroethylene 75-35-4 0.7 D030 2,4-Dinitrotoluene 121-14-2 0.134

D012 Endrin 72-20-8 0.02 D031 Heptachlor (and its epoxide) 76-44-8 0.008 D032 Hexachlorobenzene 118-74-1 0.134

D033 Hexachlorobutadiene 97-68-3 0.5 D034 Hexachloroethane 67-72-1 3.0 D008 Lead 7439-92-1 5.04

D013 Lindane 58-89-9 0.4 D009 Mercury 7439-97-6 0.2 D014 Methoxvchlor 72-43-5 10.0 D035 Methyl ethyl ketone 78-93-3 200.0 D036 Nitrobenzene 98-95-3 2.0 D037 Pentrachlorophenol 87-86-5 100.0 D038 Pyridine 110-86-1 5.0 D010 Selenium 7782-49-2 1.0 D011 Silver 7440-22-4 5.0 D039 Tetrachloroethylene 127-18-4 0.7 D015 Toxaphene 8001-35-2 0.5 D040 Trichloroethylene 79-01-6 0.5 D041 2,4,5-Trichlorophenol 95-95-4 400.0 D042 2,4,6-Trichlorophenol 88-06-2 2.0 D017 2,4,5-TP (Silvex) 93-72-1 1.0 D043 Vinyl chloride 75-01-4 0.2 mg/L -milligrams/Liter 1 Hazardous waste number.

2 Chemical abstracts service number.

3 If o-, m-, and p-Cresol concentrations cannot be differentiated, the total cresol (D026) concentration is used.

The regulatory level of total cresol is 200 mg/L.

4 Quantitation limit is greater than the calculated regulatory level. The quantitation limit therefore becomes the regulatory level.

2.3 ACUTELY HAZARDOUS WASTES

Hazardous wastes that have been determined to be extremely toxic (fatal in low doses) are designated by the EPA as acute hazardous wastes. Due to their toxicity, small amounts of these wastes are regulated in the same manner as large amounts of hazardous wastes. Examples include arsenic and cyanide compounds and a number of pesticides (e.g., dieldrin, endrin, and parathion).

The EPA list of acutely hazardous wastes is found in 40 CFR 261.33. Very little acute hazardous waste is generated at Fort Bliss.

2.4 EXEMPT WASTES

Wastes that are excluded or exempt from RCRA regulations include:

Domestic sewage routed to a publicly owned treatment works

Industrial wastewater regulated under the Clean Water Act Used oil that is recycled

Scrap metal

Spent lead acid batteries that are recycled

Containers previously used for HW, if they meet the RCRA definition of empty

2.5 NON-RCRA REGULATED WASTES

Wastes that do not meet the criteria for classification as hazardous (per RCRA) are referred to as non-hazardous wastes. Non-hazardous wastes are not covered by RCRA; however, they may be regulated by state regulations.

NOTE: DPW-E and DLA representatives will perform Classification only. Generators will not classify wastes as Class 1 Non-hazardous.

Mixing of Wastes

A non-hazardous waste becomes hazardous if mixed with a listed hazardous waste, or if mixed with a characteristic HW and the mixture still exhibits the characteristic. For example, when used oil is mixed with mogas, solvent, or other hazardous waste, the mixture is classified as a hazardous waste.

NOTE: Generators will handle non-hazardous wastes in the same manner as hazardous wastes.

Classification of the waste will be performed by DPW-E.

2.6 HAZARDOUS MATERIALS (HM)

Hazardous materials are primarily products (items that are still intended to be used for their original purpose) versus wastes. Many of the products used at Fort Bliss may be classified as hazardous materials. Examples of hazardous materials include:

Paints

Thinners

Degreasers Mogas

Adhesives

Acids

Decon Agents Calcium hypochlorite

Handling hazardous materials is regulated by the Occupational Safety and Health Administration (OSHA) and DOT regulations. Hazardous materials are not regulated by RCRA as long as they are intended for use. Once a hazardous material is discarded, it becomes a waste subject to RCRA regulations. This plan does not cover hazardous materials.

2.7 PETROLEUM, OIL, AND LUBRICANT (POL) PRODUCTS

A large number of POL products are used at Fort Bliss. In Table 2-5 are the following POL products at Fort Bliss and its classification as a hazardous or non-hazardous material.

TABLE 2-5

EXAMPLE CLASSIFICATIONS OF WASTE

Type of POL Classification Special Note Mogas Hazardous Flammable; also toxic due to presence of benzene, toluene and xylene Diesel Hazardous Flammable if flash point is < 140oF Starter solvent Hazardous PD 680 Type 2 - flammable and/or toxic Used oil Non-Hazardous If not contaminated Transmission, hydraulic, or brake fluid

Non-Hazardous If not contaminated

Grease Non-Hazardous If notcontaminated

Non-hazardous POL wastes contaminated with hazardous materials such as mogas, metals, or solvents may be hazardous waste. Characterization of these wastes as hazardous/non-hazardous is determined by analytical testing. Hazardous POL wastes are managed in the same way as other HW.

2.8 POLYCHLORINATED BIPHENYLS (PCBs)

Equipment or wastes contaminated with PCBs are regulated by the Toxic Substances Control Act (TSCA). PCB stands for polychlorinated biphenyl, a class of synthetic organic chemicals used as insulating liquids in electrical equipment and high-temperature industrial processes. While PCBs themselves are toxic, they also produce highly toxic by-products when subjected to heat. Many federal agencies have instituted programs for removal of PCBs from service. However, many PCB-containing transformers are still in service. Fort Bliss has a program for testing electrical equipment to determine if it contains PCBs. Equipment containing PCBs is removed from service and replaced with non-PCB transformers.

2.9 SPECIAL WASTES

TCEQ regulations classify certain wastes as special wastes. A special waste is defined as "Any solid waste or combination of solid wastes that because of its quantity, concentration, physical or chemical characteristics, or biological properties requires special handling and disposal to protect human health or the environment."

Fort Bliss wastes that could be classified as Special Wastes include the following:

Soil contaminated with petroleum products, crude oils, or chemicals

Pesticide containers (pesticide = insecticide, herbicide, fungicide, rodenticide)

Discarded materials containing asbestos

Grease and grit trap wastes Wastes containing PCBs in concentrations less than 50 ppm. (e.g, light ballasts and/or small capacitors)

Unlike Class 1 wastes, a special waste does not require manifesting prior to disposal. However, certain special wastes require authorization from the TCEQ prior to disposal. For example, TCEQ disposal authorization is required for a special waste with special handling requirements (such as PCBs <50 ppm). It is important to note that a waste meeting the definition of hazardous waste in 40 CFR 261 generally does not meet the definition of a special waste and therefore cannot be disposed of as special waste.

Regulated asbestos-containing materials (RACM) are considered special wastes. Proper disposal of this RACM does not require TCEQ authorization. However, if disposed of at a municipal landfill, the landfill must be TCEQ-approved to accept RACM.

NOTE: Generators will not send special waste disposal forms to TCEQ: Classification as Special Waste is performed by DPW-E.

SECTION 3 HAZARDOUS WASTE MANAGEMENT PROCEDURES

3.1 GENERAL

Under the broad definition of hazardous waste (HW), entities that generate HW and non-hazardous waste are identified as "generators." Wastes are generated as a result of maintenance and training activities, as well as spills of hazardous substances. HW storage and disposal at Fort Bliss are regulated by the EPA, the TCEQ, and the New Mexico Environment Department (NMED).

3.2 HAZARDOUS WASTE MANAGEMENT LOCATIONS

Hazardous wastes are generated at many locations throughout Fort Bliss and stored at specified sites prior to transfer to the permitted storage facility at Building 11614, as shown in Figure 3-1. These storage sites are:

Satellite Accumulation Points (SAPs) - Generated wastes are accumulated at these sites from motor pools and other activities prior to transfer to the permitted storage facility. These are temporary storage locations, at or near the point of generation. SAPs are allowed to store up 55 gallons of hazardous waste or one quart of acute hazardous waste.

90-day Storage Areas-Wastes can be stored in these areas for a total of 90 days Wastes at the SAP sites are transferred to the <90 day storage facility within 90 days. Storage of HW in a SAP or a 90-day facility does not require a RCRA permit. However, many RCRA regulations for handling and storage apply. Procedures for handling/storing wastes, as well as turn-in procedures, are presented in the next subsections.

FIGURE 3-1

SCHEMATIC OF WASTE FLOW

3.3 MANAGEMENT OF SATELLITE ACCUMULATION POINTS (SAPs)

The management of generated wastes accumulated at the SAPs at the unit level prior to transfer to the < 90-day sites will be conducted in accordance with the Satellite Accumulation Point standard operating procedure. This procedure is available as a separate stand-alone document and is found in Appendix A. SAPs must meet certain requirements to maintain compliance with RCRA regulations. These requirements, as well as specific Fort Bliss requirements, are shown in Table 3-1.

SAP

90-day site/Storage Container located at

Bldg 11614

TABLE 3-1

SATELLITE ACCUMULATION POINT REQUIREMENTS

Item RCRA Requirement Quantity A generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste as listed in 40 CFR 261.33 (e) in containers at or near any point of generation where wastes initially is collected.

SAP Designation SAPs must be numbered and marked as follows: Satellite Accumulation Point #11607, SAP #11607 a, or SAP #11607 b, etc. (according to bldg.. #)

Container Condition Containers used for storage of hazardous waste must be in good condition:

un-perforated, little or no rust, no large dents, and no bulges.

Container/Waste Compatibility

Containers must be compatible with wastes being stored. For example, battery acid must not be accumulated in metal drums.

Closed Containers The container must be kept closed, except when waste is added. Closed means sealed-ring closures locked and bungs in place.

Marking Containers The container must be marked to indicate contents.

Time Limit Once 55 gallons of hazardous waste stream is accumulated, the container(s) must be removed from the SAP within 3 days. To avoid violating the 3 day limit, call the HWFS, (915) 744-6393, when the container is 80% full.

*The HWFS team will conduct all HW RCRA pickups weekly and Non RCRA once a month.

**HWFS will have the ability to pick up Non RCRA during RCRA weekly pick-ups as time/space permits.

Universal Waste

Markings

All container condition, compatibility and closed container requirements listed above are applicable to Universal Waste in addition to the following requirements;

Mark containers with the words “Universal Waste” Fluorescent Bulbs.

“Universal Waste” Thermometers “Universal Waste” [type] Batteries “Universal Waste” Pesticides “Universal Waste” Paint or Paint Related Materials

New Mexico only “Universal Waste” Aerosol cans (all) Contact HWFS for guidance if your waste streams qualify as Universal Waste.

Universal Waste Accumulation Start Date (ASD)

All Universal Waste containers must be provided with an ASD;

Accumulation Start Date. The ASD is the date placed on the drum after the first waste went into the drum.

Accumulation Requirements

The 55-gallon accumulation requirements are not applicable to Universal Waste and Non RCRA; Units or facilities may accumulate more than 55-gallons of universal/Non RCRA waste by getting approval from the HWFS.

Storage requirements for Universal Waste Batteries

All battery terminals must be taped or batteries must be placed “individually” in plastic bags.

For guidance in proper storage of Universal Waste Batteries please contact

HWFS.

Weekly Inspections The SAP areas must be inspected weekly. Inspections, deficiencies, and corrective actions must be documented. The Weekly Inspection Checklist is located in your SAP SOP.

*The Satellite Accumulation Point Checklist is being used as the inspection tool to comply with the Spill Prevention Control and

Countermeasure Plan requirements for Secondary Containment for Drum Storage (40 CFR 112.7 (c) and 8 (c) (2).

SAP Surveillances will be conducted by the HWFS

All SAP surveillance reports will be done at the time of every pick up. No prior notifications of surveillances need to be given. HWFS will continue assisting generators comply in case of regulatory inspections.

3.4 MANAGEMENT OF 90-DAY STORAGE FACILITIES

To facilitate HW turn-in during large Field Training Exercises (FTXs), DPW-E manages and operates 90-day storage facilities at Doña Ana, McGregor, and Oro Grande Range Camps. Military units participating in FTXs transport waste from SAPs to the 90-day facilities. Figure 3-3 shows the 90-day storage units at the following locations:

Doña Ana Range Camp - Buildings 8167, 8168 McGregor Range Camp - Buildings 9491, 9492 Oro Grande Range Camp - Building 8641, northeast area East Fort Bliss (5) - Building 11614 Main Cantonment - Building 2423A

All 90-day facilities are temporary HW storage areas; all must comply with environmental laws. RCRA regulations applicable to 90-day facilities are contained in 40 CFR 262 and 40 CFR 264 Subparts C, D, and I.

These requirements are summarized in Table 3-2.

TABLE 3-2 90-DAY STORAGE FACILITY REQUIREMENTS

Item RCRA Requirement

Accumulation Time

Wastes must not be stored at these facilities for more than 90 days. Arrangements must be made to have wastes picked up for disposal or to transfer wastes to the <90 day storage facility located at Building 11614 before the 90-day period expires.

Storage Date The Accumulation Start Date (ASD) on which the waste container was placed in the 90-day area must be marked on the container

Container Management

The following requirements specified earlier for SAPs are also applicable to 90-day areas: Closed containers, Container condition, Compatibility with waste stored

Labeling Containers

The container must be marked "Used Oil" to indicate contents. Containers should be placed so that all markings and labels are visible. ALL USED OIL

CONTAINERS MUST HAVE A LABEL PROVIDED BY THE HWFS

PROGRAM.

Containment Area

Containers must be stored on an impervious surface that is free of cracks.

Secondary containment will be provided in areas used to store waste liquids.

Aisle Space Adequate aisle space must be provided between rows of containers to allow access for visual inspection of each container.

Weekly Inspections

The 90-day storage areas must be inspected weekly. Inspections, deficiencies, and corrective actions must be documented.

Personnel Training

Facility personnel must have the required OSHA training contained in 29 CFR

1910.120 and training in accordance with RCRA requirements in 40 CFR 265.16.

Contingency All <90 day storage units have their own Contigency Plans in which their units

Plan reflect site specific info.

Preparedness and Prevention

All of the Fort Bliss 90-day facilities are equipped with modular buildings and or canopies designed for storage of hazardous substances. The sites have fire-control equipment, secondary containment, security fencing, warning signs, and emergency showers. Site operators have telephones and radios for summoning assistance. Equipment must be tested and maintained to ensure proper operation.

3.4.1 Container Storage Area Requirements

The storage area must be in compliance with the following RCRA and Fort Bliss requirements:

All containers correctly labeled.

Sufficient aisle space (3 feet) between rows of containers. .

Containers stacked no more than two high. Containers that are stacked must have a pallet between the first and second level.

Adequate supply of personal protective equipment.

Operating fire alarm and fire extinguisher. Periodically, the alarm must be tested and the extinguisher must be checked to verify that it is charged and operable.

Maintain a Waste Inventory Log Maintain Universal Waste Logs see Table 3-3

TABLE 3-3

WASTE INVENTORY LOG 90-DAY STORAGE FACILITY

Fort Bliss Hazardous Waste <90 Day Log In

Tech

Dropped Off Date A.S.D.

90 Day Expired

Date

Document

Waste Description

# of Containers

DRMO

Turn-In

Date

Sample

Sample Date Weight

3.4.2 Incompatible Waste Storage

Some of the hazardous wastes generated at Fort Bliss are not compatible; storage of such wastes in proximity to one another presents a safety risk. For example, containers with battery acid should not be stored adjacent to alkaline materials such as DS-2. Spilled liquids from these containers could mix, resulting in heat generation and/or violent reaction. RCRA regulations require that incompatible wastes be separated by a berm, wall or other device. Each modular building at the 90-day storage areas is divided into two sections by a barrier wall.

Incompatible wastes should be stored in different sections.

Determination of these properties can be made from the SDS. Table 3-4 is a Hazardous Materials Wastes Storage Incompatibility Chart developed by the U.S. Army Construction Engineering Research Laboratories.

TABLE 3-4 HAZARDOUS MATERIALS/HAZARDOUS WASTE STORAGE INCOMPATIBILITY

CHART

If the Material Contains:

It May Not Be Stored With Any of the Following:

Acid (pH below 2.0)

Caustics (pH above 12.5), Reactive Metals, Alcohol, Water, Aldehydes, Halogenated, Nitrated, or Unsaturated Hydrocarbons Reactive Organic Compounds and Solvents, Spent Cyanide and Sulfide Solutions, Oxidizers

Caustic (pH above 12.5) Acid (pH below 2.0), Reactive Metals, Alcohol, Water, Aldehydes, Halogenated, Nitrated, or Unsaturated Hydrocarbons, Reactive Organic Compounds and Solvents

Reactive Metals Caustics Acids, Alcohols, Aldehydes, Halogenated, Nitrated, or Unsaturated Hydrocarbons, Reactive Organic Compounds and Solvents Oxidizers

Reactive Organic Compound Solvents Caustics, Acids, or Reactive Metals

Spent Cyanide and Sulfide Solutions

Acids

Oxidizers Acetic or Other Organic Acids, Concentrated Mineral Acids, Reactive Metals, Reactive Organic Compounds and Solvents, Ignitable* (Flammable/Combustible) Wastes

Examples of Bolded items from above Ignitable*

(Flammables/Combustibles) Carburetor Cleaners, Engine Cleaners, Epoxy, Resins, Adhesives, and Rubber Cements, Lacquers Paints, Paint Thinners, Pesticides that contain Solvents (such as Methyl Alcohol, Ethyl Alcohol, Isopropyl Alcohol, Toluene, Xylene), Petroleum Solvents (Dry-cleaning Fluid), Solvents: Acetone, Benzene, Carbon Tetrachloride (Carbon Tet), Ethanol (Ethyl Alcohol), Ethyl Benzene, Isopropanol (Isopropyl Alcohol), Corrosives Acids Caustics

Battery Acids, Degreasers and Engine Cleaners, Etching Fluids, Hydrobromic Acid, Hydrochloric Acid, Muriatic Acid, Nitric Acid (>40%), Phosphoric Acid, Rust Removers, Naval Jelly, Sulfuric Acid, Oil of Vitriol

Acetylene sludge, Alkaline Battery Acids, Alkaline Cleaners, Alkaline Degreasers, Alkaline Etching Fluids, Lime and Water Lime, Wastewater, Potassium Hydroxide, Caustic Potash, Rust Removers, Sodium Hydroxide, Caustic Soda, Soda Lye

Reactive Metals

Reactive Organic Compounds & Solutions

If the Material Contains:

It May Not Be Stored With Any of the Following:

Kerosene (Fuel Oil #1), Methanol (Wood Alcohol), Methyl Ethyl, Ketone (MEK), Petroleum Distillates, Tetrahydrofuran (THF), Toluene (Methacide, Methylbenzene, Methylbenzol, Phenylmethane, Toluol, Antisal 1A), White Spirits, (White Spirits, Mineral Spirits, Naphtha), Xylene (Xylol), Stains, Stripping Agents, Varsol, Waste Fuels, Waste Ink, Wax Removers, Wood Cleaners

Lithium Batteries, Aluminum, Beryllium, Calcium, Magnesium, Sodium, Zinc Powder

Alcohol, Aldehydes, Chromic Acids (from chrome plating, copper stripping and aluminum anodizing), Cyanides (from electroplating operations), Hypochlorite (from water treatment plants, swimming pools, sanitizing operations), Organic Peroxides (including Hydrogen Peroxide), Perchlorates, Permanganates, Sulfides

Oxidizers Chlorine Gas, Nitric Acid (>40%), Red Fuming Nitric, Nitrates, Sodium Nitrate, Ammonium Nitrate, Perchlorates, Perchloric Acid, Peroxides, Calcium Hypochlorite (>60%)

* “Ignitable” in this context refers to substances with a flashpoint at and below 140° F, and includes:

Combustible substances, with a flashpoint below 140° F Flammable substances, with a flashpoint below 100° F

3.5 HAZARDOUS WASTE STORAGE FACILITY OPERATIONS

Fort Bliss has a (5) <90 day storage facilities located at Building 11614, East Fort Bliss. Hazardous wastes generated at Fort Bliss are taken to Building 11614 for storage prior to off-site shipment for disposal.

3.5.1 HW Storage Facility Information

TCEQ Solid Waste Registration Number – 63003

<90 day storage units information and capacity is provided in Table 3-5.

TABLE 3-5

HAZARDOUS WASTE STORAGE FACILITY INFORMATION

Management Storage Units Capacity Unit 2 (concrete pad) 31,900 gallons, no free liquids

Unit 108 (Concrete pad) 31,900 gallons Unit 109 (Building 11605) 31,900 gallons

Unit 116 (Formerly Mgmt Unit 6,7,8,9) 3 Modular Buildings and 1 Concrete

Pad)

150,000 gallons Building 11612; ignitable wastes Building 11611; corrosive wastes

Building 11610; Toxic wastes Pad

Unit 117 (Bldg 11614) 8,800 gallons of free-liquid wastes

3.5.2 Responsibilities

DLA Specific duties include:

Receipt of wastes turned-in by generators

Off-site shipment of wastes

Contract for off-site disposal of wastes stored at Building 11614

Sign manifests and prepare exception reports

DPW-E HW Program (contractor) is responsible operation of the HWFS. Specific duties include:

Operates and maintains hazardous waste <90 day storage facilities.

Pick up wastes at SAP sites

Provide replacement drum for each 55-gallon drum of waste turned in

Complete Form 1348-1A and hazardous waste profile sheets (Figures 3-7 and 3-8)

Transport wastes to the HWSF <90 day Storage Facilities

1348-1a input into the ETID system.

Prepare, review, sign, and track Manifests.

Note: The requirements and other information for the above section can be found in the SAP SOP.

3.6 HW TRANSPORTATION REQUIREMENTS

Transport of HW is regulated by the Department of Transportation (DOT). Any person engaged in the transportation of HW off-post must be trained in accordance with DOT requirements as defined in 49 CFR 106 and 180.

3.7 RECORDKEEPING AND REPORTING REQUIREMENTS

Recordkeeping and reporting requirements are defined in 40 CFR 262. Records will be maintained in electronic format where applicable and will be available to regulatory personnel when requested.

TABLE 3-10

REPORT SUBMISSION REQUIREMENTS

TYPE PREPAROR DUE SUBMITTED TO

Annual Waste Shipment Summary3a

DPW-E 1 March TCEQ

Exception Report (for failure to receive return copy of Manifest from disposal facility)2

DLA

DPW-E

45th day after initiation of HW Manifest 46 days after initiation of HW manifest

TCEQ/EPA

TCEQ/EPA

Additional Reporting DPW-E As determined by TCEQ3a/NMED3b/EPA3c

Requesting Agency

Site Activity Report3a DPW-E 1 March TCEQ Waste Minimization Report4

DPW-E 1 October TCEQ

New Mexico Biennial Report

DPW-E 1 March NMED

PCB LOG DPW-E July 1 DPW-E 1 = Title 40 CFR, Part 270.5 2 = Title 30 TAC, Part 1 Chapter 335 Subchapter A Rule 335.13 3a = Title 30 TAC, Part 1 Chapter 335 3b = NMAC Title 20.4 Part 2 3c = Title 40 CFR Part 271.11 4 = Title 30 TAC, Part 1, Chapter 335, Subchapter Q, Rule 335.476

TABLE 3-11

RECORD KEEPING REQUIREMENTS

RECORD OWNER RETENTION PURPOSE

SAP Weekly Inspection Log HW Generator 3 years Accumulation DD Form 1348-1A HW Generator, DLA,DPW-E

3 years Disposal

Monthly Waste Shipment Summary DPW-E 3 years Storage/Disposal Annual Waste Shipment Report DPW-E 3 years Storage/Disposal Exception Report DLA 3 years Storage/Disposal Test Result Waste Analysis DPW-E 3 years Storage/Disposal HW Manifests DLA/ DPW-E 3 years Transportation Training Records HW Generator, DPW-E, DLA

3 years Verification

SECTION 4 TRAINING REQUIREMENTS

4.1 GENERAL

Government agencies such as the Department of Transportation (DOT), Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA) and Department of Defense (DOD) have established training standards for employees involved in HW operations. The objective is to ensure that personnel are aware of the danger associated with the hazardous substances they must handle, and to ensure proper HW management from the accumulation point through ultimate disposal.

Personnel assigned to HW duties at Fort Bliss must successfully complete a program of classroom instructions or on-the-job training that teaches them to perform duties in compliance with regulations.

DPW-E has established training standards for Fort Bliss personnel involved in HW operations. Refer to the Table 4.1 for training requirements for various job categories.

4.2 TRAINING RESPONSIBILITIES

4.2.1 DPW-Environmental Division

Ensure all personnel with hazardous waste management duties have received the required training.

Develop training requirements for personnel handling HW at satellite accumulation points.

Supplement training for waste generators -through classroom (Monthly Generator’s Meeting) and on-the job instruction -o Packaging o Marking o Inspections o Forms and Records o Reports o Spill Reporting o Safety Procedures o Storage Requirements o Emergency Procedures o Hazardous Waste Minimization/Substitution

4.2.2 Generators

Identify personnel who operate Satellite Accumulation Points (SAPs) and contact the HWFS (915) 744-6393, to schedule RCRA Awareness Training.

4.2.3 Installation Safety Office

In accordance with OSHA requirements, provide Hazard Communication (HAZCOM) training for personnel who work with hazardous chemicals. The training will address Safety Data Sheets (SDSs);

personal protective equipment, and the use/storage/disposal of hazardous chemicals.

4.3 TRAINING STANDARDS

Training requirements for personnel handling HW are established by DOT, EPA, and OSHA regulations. DPW-E developed training standards to ensure that all Fort Bliss personnel involved in HW operations are aware of regulatory requirements. The standard lists required training for various job categories or tasks.

Unit supervisors are responsible for ensuring that personnel obtain required training. It is essential that HW training be documented and placed in employees' records and that training records accompany personnel to new assignments. Training required by EPA, OSHA, and DOT regulations is described below.

4.3.1 Hazard Communication Standard (HAZCOM)

In 29 CFR 1910.1200, OSHA delineated workers "right to know" about the hazards associated with chemicals in the workplace. Each activity that uses hazardous materials must maintain a library of Safety Data Sheets (SDSs) in a location that is readily accessible to employees. Additional employer requirements, such as labeling all hazmat containers, and keeping a complete inventory, are detailed in the HAZCOM training. The Installation Safety Office is responsible for monitoring HAZCOM training.

4.3.2 Respiratory Protection

Supervisors will learn, upon reviewing SDSs for the hazardous materials utilized at their activities, that some of their employees must wear respirators. In such cases, each employee must have written approval from an occupational health physician to wear the appropriate respirator; and the employer must establish a respiratory protection program to include training on the use, care, and limitations of respirators. AR 11-34, 15 Feb 90, The Army Respiratory Protection Program, provides detailed training/program guidance to ensure compliance with 29 CFR 1910.134.

4.3.3 Hazardous Material Waste Clean-up; Spill Response

Training requirements, as stated in OSHA 20 CFR 1910, 1917, and 1926, apply to:

Hazardous substance response operations under CERCLA Major corrective actions taken in hazardous waste operation sites designated for clean up under RCRA

Additional training requirements, pertaining to HW spill management, are contained in 40 CFR

264.16 and 265.16. The 49 CFR 171.3 indicates that personnel must be instructed to fulfill DOT packaging and transportation requirements, including proper labeling, marking, and packaging of the resultant spill waste.

4.3.4 Hazardous Waste Transportation

Personnel involved in transporting hazardous wastes must have the training required by DOT regulations contained in 49 CFR 106 to 180. Vehicles used for transporting the waste must have appropriate DOT placards. Privately owned vehicles are prohibited from transporting hazardous waste on Fort Bliss. Training requirements for HW transporters are listed in Table 4-1 (following page).

TABLE 4-1

TRAINING REQUIREMENTS FOR

HAZARDOUS WASTE HANDLERS AND TRANSPORTERS

TASK DESCRIPTION TRAINING

SATELLITE ACCUMULATION POINTS1

Unit HW Handler

Includes managers and employees at activities that generate (or otherwise manage) HW.

SAP operator and individuals that place waste in SAP.

RCRA Awareness Training

HW CLEAN-UP, SPILL RESPONSE, 90-DAY STORAGE SITES2

Managers and Supervisors

40 hours of initial instruction of HAZWOPER training At least 8 hours of specialized training on managing hazardous waste operations 8-hour annual refresher

Emergency Response Teams at HW sites

HW Site Worker (includes personnel exposed to hazardous materials such as general laborers and equipment operators)

Minimum of 40 hours of initial HAZWOPER instruction off-site Minimum 3 days supervised field experience 8-hour annual refresher for HAZWOPER

HW Site Worker

Specific Limited Task (example: Surveying) 24 hours initial training 1 day supervised field experience 8-hour annual refresher

Emergency Response Teams

Spill Response Teams Hazardous Materials Teams

At least 24 hours initial training Monthly training sessions, or for…