TE 31 Disposal of Hazardous Material Combined.pdf

Regulations Description

AR 200 - 1 Army Environmental Protection and Enhancement

40 CFR 261 Identification and Listing of Hazardous Waste

40 CFR 262 Standards applicable to Generators of Hazardous Waste

40 CFR 273 Standards for Universal Waste

40 CFR 279 Standards of the Management of Used Oil

*YPG Handbooks Subject to Revisions*

YPG Used Oil Management Plan

YPG Environmental Handbook

TECHNICAL EXHIBIT 31

Disposal of Hazardous Material List

YPG Environmental Handbooks Attached

YPG Hazardous Waste Management Plan

YPG Universal Waste Management Plan

HAZARDOUS WASTE MANAGEMENT PLAN

U.S. ARMY YUMA PROVING GROUND

U.S. Army Garrison Yuma Proving Ground Environmental Sciences Division

Yuma, Arizona 85365

Revision: February 2018

This Page Intentionally Left Blank

Hazardous Waste U.S. Army Garrison Management Plan Yuma Proving Ground

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Table of Contents

1. PURPOSE

2. SCOPE

3. REGULATORY BACKGROUND

3.1 Army Regulation 200-1

3.2 Resource Conservation and Recovery Act

3.3 Hazardous and Solid Waste Amendments

3.4 Pollution Prevention Act

3.5 Executive Order 12856; Federal Compliance with Right-to-Know Laws and Pollution Prevention requirements

3.6 The Federal Facilities Compliance Act

3.7 Comprehensive Environmental Response, Compensation, and Liability Act

3.8 EO 12088; Federal Compliance with Pollution Standards

3.9 The Toxic Substances Control Act

4. GENERAL FACILITY DESCRIPTION

5. GENERATOR STATUS

6. CONTACTS

7. RESPONSIBILITIES

7.1 Garrison Manager

7.2 Environmental Quality Control Committee

7.3 Unit Commanders / Civilian Supervisors

7.4 Environmental Sciences Division

7.5 Training Coordinator

7.6 Directorate of Logistics (DOL) and Contractor

7.7 <90-Day Storage Facility

7.8 Commander, Yuma Test Center

7.9 Defense Reutilization and Marketing Office

7.10 Directorate of Contracting

7.11 Safety Division

7.12 YPG Fire Department

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7.13 Preventative Medicine Office

7.14 Environmental Compliance Coordinators

8. SPILL RESPONSE

9. HAZARDOUS WASTE IDENTIFICATION

9.1 Identification of Waste

9.2 Hazardous Waste Profiles

10. HAZARDOUS WASTE MANAGEMENT FACILITY

11. OPEN BURN / OPEN DETONATION FACILITY

12. HAZARDOUS WASTE ACCUMULATION AND STORAGE

12.1 Container Management

12.1.1 Container Compatibility

12.2 Hazardous Waste Management Facility Disposition Bins

12.3 Satellite Accumulation Point

12.4 <90-Day Storage Site

12.5 Site Requirements

12.6 Quantity and Time Limitations

12.7 Required Facility Signage

12.8 Facility Inspections

12.9 Secondary Containment

13. HAZARDOUS WASTE HANDLING OVERVIEW

13.1 Known Wastes

13.2 Commonly Overlooked Wastes

13.2.1 Shop Rags

13.2.2 Aerosol Cans

13.2.3 Flameless Ration Heaters

13.2.4 Munitions

13.2.5 Parts Washers

13.3 Unknown/Abandoned Wastes

13.4 Waste Turn-In

13.5 Universal Waste

14. NON-RCRA REGULATED WASTE MANAGEMENT

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14.1 Asbestos

14.2 Petroleum Contaminated Soil

14.3 Used Petroleum, Oils, and Lubricants (POLs)

15. INSPECTIONS

16. TRANSPORTING

16.1 Manifests

16.2 Special Waste Manifests and Reporting

17. TRAINING

18. RECORD KEEPING AND REPORTING

List of Tables

Table 12-1: Container Compatibility Chart

Table 15-1: Potential Inspection Criteria

Table 17-1: Training Requirements

Table 18-1: Records Maintenance

List of Appendices

APPENDIX A – Universal Waste Management Plan APPENDIX B – Hazardous Waste Analysis Plan APPENDIX C – Hazardous Waste Management Facility Standard Operating Procedures APPENDIX D – Rags and Wipes Management (Quick Guide) APPENDIX E – Compatibility Chart APPENDIX F – Satellite Accumulation Point Plan APPENDIX G – Used Oil Management Plan

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Acronyms and Abbreviations

AAC Arizona Administrative Code ADEQ Arizona Department of Environmental Quality AERO Army Environmental Reporting Online AR Army Regulation CERCLA Comprehensive Environmental Response, Compensation, and Liability

Act CFR Code of Federal Regulations DIDC Document Information and Data Control DLA Defense Logistics Agency DoD Department of Defense DOL Directorate of Logistics DOT Department of Transportation DPW Department of Public Works DRMO Defense Reutilization and Marketing Office ECC Environmental Compliance Coordinator EO Executive Order EPA U.S. Environmental Protection Agency EPCRA Environmental Protection and Community Right-to-Know Act EQCC Environmental Quality Control Committee ESD Environmental Sciences Division FFCA Federal Facilities Compliance Act FRH Flameless Ration Heater GET General Environmental Training HAZWOPER Hazardous Waste Operations and Emergency Response HWMP Hazardous Waste Management Plan HWP Hazardous Waste Profile IEC Installation Environmental Coordinator kg kilogram LQG Large Quantity Generator OB/OD Open Burn / Open Detonation ODS Ozone Depleting Substance OSHA Occupational Safety and Health Administration PCB Polychlorinated Biphenyl PCS Petroleum Contaminated Soil POL Petroleum, Oils, and Lubricants PPA Pollution Prevention Act PPE Personal Protection Equipment RCRA Resource Conservation and Recovery Act

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Acronyms and Abbreviations

SAP Satellite Accumulation Point SARA Superfund Amendments and Reauthorization Act SDS Safety Data Sheet SOP Standard Operating Procedures SPCC Spill Prevention Control and Countermeasures TSCA Toxic Substances Control Act YPG Yuma Proving Ground YTC Yuma Test Center

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1. Purpose This Hazardous Waste Management Plan (HWMP) has been developed to provide guidance to all U.S. Army Garrison Yuma Proving Ground (YPG) personnel who work with hazardous waste. This plan incorporates regulatory requirements covering hazardous waste by the U.S.

Environmental Protection Agency (EPA), Arizona Department of Environmental Quality (ADEQ), Occupational Safety and Health Administration (OSHA), and the U.S. Army. This HWMP serves as a tool to help YPG meet regulatory compliance by establishing procedures for properly managing hazardous waste in accordance with these applicable laws and regulations, and is intended to ensure a safe and healthy environment. This HWMP also provides guidance pertaining to the identification, characterization, accumulation, collection, transportation, storage, planning, emergency response, training, and record keeping for hazardous waste. In addition to hazardous waste, this plan also addresses management of other commonly overlooked hazardous waste and non-hazardous wastes that may be regulated under specific conditions (i.e., used oil). This HWMP is reviewed annually, at a minimum, by the YPG Environmental Sciences Division (ESD) and updated as needed.

2. Scope This HWMP applies to all units and activities physically located on YPG. All military, civilian, and contract personnel working for YPG are subject to the policies and standing operating procedures (SOPs) outlined in this HWMP. The implementation of this plan is consistent with federal, state, and local hazardous waste requirements.

3. Regulatory Background The passage of the Resource Conservation and Recovery Act (RCRA) of 1976 and subsequent amendments, as well as the Federal Facilities Compliance Act of 1992 (FFCA), made it mandatory for the Department of Defense (DoD) to adopt more effective methods of managing hazardous waste.

3.1 Army Regulation 200-1

Chapter 10 of Army Regulation (AR) 200-1 Update, entitled Environmental Protection and Enhancement (dated December 13, 2007), defines Army policy and procedures for managing hazardous waste, including resource recovery, recycling, waste reduction, and training programs.

Section 10-1 (d)(3) deals specifically with HWMPs and states that the Installation Commander must ensure that a written HWMP is maintained to provide installation personnel with procedures and responsibilities to manage hazardous wastes consistent with federal, state, and local laws and regulations. The ESD (or their designee) will prepare the plan and provide copies to all facility personnel, including tenants that generate, transport, treat, store, and dispose of hazardous waste.

3.2 Resource Conservation and Recovery Act

The RCRA was enacted in 1976 as an amendment to the Solid Waste Disposal Act. The primary objectives of RCRA are to protect human health and the environment, and conserve valuable material and energy resources. The most important aspect of RCRA that affects YPG is its establishment of “cradle-to-grave” management and tracking of hazardous waste, from point of

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2 February 2018 generation to point of disposal. Other aspects of RCRA include the development of solid waste management plans; prohibition of open dumping; encouragement of recycling, reuse, and treatment of hazardous wastes; establishment of guidelines for solid waste management; and the promotion of beneficial solid waste management, resource recovery, and resource conservation systems. Under its corrective action provision, RCRA also regulates cleanup of contamination, much like the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, or “Superfund”). However, RCRA concentrates on active, regulated facilities, while CERCLA focuses on inactive or uncontrolled sites.

3.3 Hazardous and Solid Waste Amendments

The Hazardous and Solid Waste Amendments, enacted in 1984, reauthorized and amended RCRA and imposed new and far-reaching requirements on the management of hazardous waste.

The amendments established programs to regulate small quantity generators of hazardous waste (between 100 and 1,000 kilograms [kg] of waste per month), restricted land disposal of hazardous waste, established minimum technology requirements for land disposal units, required corrective actions for releases of hazardous waste, regulated underground storage tanks containing petroleum products of hazardous substances, initiated listing of new materials as hazardous wastes, and set deadlines for EPA to issue or deny hazardous waste facility operating permits.

3.4 Pollution Prevention Act

According to the Pollution Prevention Act of 1990 (PPA), it is the policy of the United States that, whenever feasible, pollution should be prevented or reduced at the source; that pollution which cannot be prevented should be recycled in an environmentally safe manner; that pollution which cannot be prevented or recycled should be treated in an environmentally safe manner; and that disposal or other releases into the environment of waste should be employed only as a last resort and should be done in an environmentally safe manner.

3.5 Executive Order 12856; Federal Compliance with Right-to-Know Laws and

Pollution Prevention requirements The Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) established programs to provide the public with important information on the hazardous and toxic chemicals in their communities. It also established emergency planning and notification requirements to protect the public in the event of a release of hazardous substances at or above their respective reportable quantities.

Executive Order (EO) 12856 (August 3, 1993) orders that “the head of each Federal Agency is responsible for ensuring that all necessary actions are taken for the prevention of pollution with respect to that agency’s activities and facilities, and for ensuring that agency’s compliance with pollutions prevention and emergency planning and community right-to-know provisions established pursuant to all implementing regulations issued pursuant to EPCRA and PPA.”

3.6 The Federal Facilities Compliance Act

The FFCA provides for a waiver of sovereign immunity with respect to federal, state, and local procedural and substantive requirements under RCRA solid and hazardous waste laws and regulations. Additionally, it defines hazardous waste in relation to public vessels, expands the

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3 February 2018 definition of mixed waste, addresses the issue of munitions, and discusses waste discharges to federally-owned treatment works. The FFCA makes all federal agencies responsible for compliance with all regulation and requirements applicable to hazardous waste management and reporting requirements.

3.7 Comprehensive Environmental Response, Compensation, and Liability Act CERCLA established the “Superfund” to finance and control the cleanup of hazardous waste that was disposed of prior to 1983. This act was amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986. The SARA regulates the prevention, control, and compensation of environmental pollution. The SARA defines requirements for “Community- Right-to-Know,” which informs, trains, and enables local emergency response organizations to protect the populace from damage from hazardous waste releases.

3.8 EO 12088; Federal Compliance with Pollution Standards

EO 12088 (October 13, 1978) requires federally-owned and operated facilities to comply with applicable federal, state, and local pollution control standards. The EO makes the head of each executive agency responsible for seeing that the agencies, facilities, programs, and activities it funds meet applicable, federal, state, and local environmental requirements and for correcting non-compliance with such requirements. In addition, the EO requires that each agency ensure that sufficient funds for environmental compliance are included in the agency budget.

3.9 The Toxic Substances Control Act

The Toxic Substance Control Act (TSCA) regulates the manufacture, importation, and control of certain toxic substances, including pesticides, asbestos containing materials management, asbestos hazard emergency response, and indoor radon abatement. The management of polychlorinated biphenyls (PCBs)-containing materials and waste are governed under TSCA.

4. General Facility Description YPG is a military installation encompassing 837,120 acres (1,308 square miles) of Sonoran Desert in southwest Arizona. The installation is used by DoD primarily to test and evaluate a variety of military systems. In addition, transient military units deploy to the installation for temporary testing, training, or mission support.

There are numerous facilities located throughout YPG that perform industrial activities in support of the installation mission. These activities include vehicle and equipment maintenance and cleaning, painting, fueling, fuel and chemical storage, material handling, cleaning and janitorial services, as well as hazardous and non-hazardous waste management and disposal.

While these activities are performed throughout YPG, most are concentrated within four cantonment areas: (1) Kofa Firing Range, (2) Laguna Army Airfield, (3) Howard Cantonment Area (formerly known as Main Administrative Area), and (4) Walker Cantonment Area (formerly known as Yuma Test Center). Performance activities are also concentrated within two remote areas: (1) Castle Dome Annex and (2) Castle Dome Heliport.

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5. Generator Status YPG is considered to be a large quantity generator (LQG) of hazardous waste. The EPA and ADEQ have more stringent requirement for LQGs than small quantity generators. LQGs generate 1,000 kg per month or more of hazardous waste, or more than 1 kg per month of acutely hazardous waste. Requirements for LQGs are as follows:

• May only accumulate hazardous waste on site for 90 days (exceptions apply)

• No limit on the amount of hazardous waste that may be accumulated

• An employee must always be available for emergency response

• Must have contingency plans for handling emergencies.

6. Contacts

Emergency Contact/Fire Department (928) 328-2949 YPG Spill Coordinator (928) 920-1736 Hazardous Waste Manager (928) 328-2674 Hazardous Waste Management Facility (928) 328-2828

7. Responsibilities In order to meet federal and state requirements, supervisors and commanders at YPG are responsible for providing command emphasis and guidance to all persons working with hazardous waste. To help prevent personal injury or harm to public health and the environment, concerted efforts must be made by all YPG personnel to ensure the safe handling, control, storage, and disposal of hazardous waste. This section provides detailed listings of specific responsibilities related to hazardous waste management.

7.1 Garrison Manager

The position of the Garrison Manager is equivalent to that of a Commander at YPG. The Garrison Manager is responsible for all requirements found in AR 200-1, Environmental Protection and Enhancement. Specific responsibilities of the Garrison Manager are as follows.

• Complies with applicable federal, state, and local environmental laws, regulations, internal directives, goals, and EO(s)

• Chairs the Environmental Quality Control Committee (EQCC) (AR 200-1 [15-2.a])

• Investigates regulatory enforcement actions, complaints, spills/releases, and corrects systematic problems

• Documents investigation, negotiation, and resolution of enforcement actions and submits through the respective chain of command and through technical legal channels

• Applies for, signs, arranges funding, and maintains all applicable federal, state, and local environmental permits

• Maintains appropriate environmental records, as required by law

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• Records enforcement actions within 48 hours via the Army Environmental Reporting Online (AERO) portal

• Ensures that non-DoD hazardous material (i.e., hazardous material owned and/or used by non-DoD entities) is not stored, treated, or disposed of on the installation unless approved by the installation command (i.e., his/her designee or higher authority)

• Implements an installation-wide Hazardous Materials Management Program

• Promotes recycling/reuse programs and Green Procurement policies.

7.2 Environmental Quality Control Committee

The EQCC will be established in accordance with AR 200-1 (15-2) and should consist of members representing all aspects of the installation. This includes, but is not limited to, operational; logistics; resource management; legal; medical; and Morale, Welfare, and Recreation. Specific responsibilities of the EQCC are as follows.

• Provide assistance in the planning, executing, and monitoring actions and programs with environmental implications (AR 200.1 [15-2.c])

• Identify issues, make recommendations, and advise the Garrison Manager as it relates to environmental activities, issues, and concerns (AR 200.1 [15-2.c])

• Meet at least quarterly, or as necessary, to discuss hazardous waste issues, policy, regulations, and address any changes or areas of concern (AR 200.1 [15-2.a]).

7.3 Unit Commanders / Civilian Supervisors

Unit Commanders and Civilian Supervisors play essential roles in ensuring proper hazardous waste management at YPG. Specific responsibilities are as follows.

• Provide command emphasis regarding environmental compliance

• Ensure that the YPG Hazardous Waste Management Facility is informed of all hazardous materials purchased by the unit/activity and that the hazardous material is barcoded for tracking within the current hazardous material tracking system managed by the ESD and the Hazardous Waste Management Facility

• Appoint, in writing, a unit facility Environmental Compliance Coordinator (ECC)

• Ensure that the ECC has sufficient personnel and resources to carry out the unit’s environmental compliance mission

• Ensure that resources are available to train ECCs

• Appoint a unit/activity hazardous material custodian.

7.4 Environmental Sciences Division

The YPG ESD serves as the installation environmental coordinator (IEC) under the Directorate of Public Works (DPW). The ESD has a staff and an environmental support services contractor to assist in daily environmental compliance oversight. Specific responsibilities are as follows.

• Serve as a member of the EQCC (AR200.1 [15-2.b])

• Develop, maintain, implement, update, and distribute YPG's HWMP

• Maintain a liaison between activities on YPG and federal, state, and local authorities on meeting their standards for collection, storage, and disposal of hazardous wastes

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• Review contracts for compliance with environmental regulations and policies

• Coordinate, inspect, and manage all aspects of installation actions regarding the handling of hazardous waste

• Provide technical expertise to activities

• Notify generating activities/units of deficiencies identified during site inspections and provide guidance, as required, to correct deficiencies

• Conduct biennial reporting requirements and file required reports with ADEQ

• Initiate processes to replace hazardous material with less hazardous or non-hazardous materials

• Ensure that information pertaining to new hazardous waste policies and procedures are communicated to the facility ECCs.

7.5 Training Coordinator

The YPG training coordinator, as it relates to hazardous waste management, is a designated personnel member from the ESD. The specific responsibilities of the training coordinator are as follows.

• Coordinates the hazardous waste training schedule

• Provides training to personnel identified as ECCs by the activities.

7.6 Directorate of Logistics (DOL) and Contractor

The Directorate of Logistics (DOL) oversees the installation and procurement of hazardous materials. The DOL maintains a support services contract that manages the procurement and distribution of hazardous materials on the installation. Specific responsibilities of the DOL are as follows.

• Procures hazardous material through an Army-wide or other approved procurement system.

7.7 <90-Day Storage Facility The facility is managed by the ESD under a support services contract. IEC personnel work closely with the IEC to ensure that all hazardous wastes are handled properly and in an effective manner. Specific responsibilities of <90-Day Storage Facility personnel are as follows.

• Track all hazardous waste utilizing the current required hazardous materials and waste tracking database

• Assist in hazardous material reutilization

• Promote pollution prevention initiatives

• Maintain paper/audit trail of hazardous waste from the point of generation to disposal

• Coordinate with the Defense Reutilization and Marketing Office (DRMO) for hazardous waste pick-up and disposal

• Advise, as needed, waste generating activities of proper requirements for packaging, labeling, and handling of hazardous waste to ensure compliance with federal, state, and local regulations

• Coordinate and manage the recycling of universal or special waste (i.e., batteries and used oil) in accordance with the YPG Universal Waste Management Plan (see Appendix A).

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7.8 Commander, Yuma Test Center

The Yuma Test Center (YTC) Commander oversees non-garrison test functions and training units at YPG. The Commander receives guidance from the IEC regarding hazardous material and hazardous waste on YPG. Responsibilities of the YTC Commander are as follows.

• Secures environmental agreements from training units and test projects

• Provides visiting units with a copy of this HWMP and access to YPG’s Hazardous Waste

Management Facility.

• Informs the YPG Fire Department, ESD, and the Hazardous Waste Management Facility of all hazardous material entering YPG as part of training or test exercises.

7.9 Defense Reutilization and Marketing Office

The DRMO is utilized by various DoD entities as its primary means of disposal for accountable equipment and hazardous waste. The specific responsibilities of the DRMO are as follows.

• Operate under guidelines published by the Defense Logistics Agency (DLA) and DoD

• Determine marketability of all DoD-owned hazardous material/hazardous waste for proper sale, reuse, or disposal

• Dispose of and/or arrange to dispose of hazardous waste

• Provide unit disposal costs for each hazardous waste stream

• Contract for hazardous waste disposal in accordance with DoD 4160.21-M, Chapter XI and

DLAM 6050.1 and comply with all federal, state, and local regulations

• Issue instructions regarding hazardous waste turn-in for generating activities.

7.10 Directorate of Contracting

• Serves as member of the EQCC (AR 200.1 [15-2.b])

• Coordinates with the ESD to review contracts for the handling of any hazardous waste that may be generated while a contractor works on post

• Ensures contracts for outside services include provisions for the proper management of hazardous waste.

7.11 Safety Division

• Serves as member of the EQCC (AR 200.1 [15-2.b])

• Assists the ESD with the implementation of this HWMP.

7.12 YPG Fire Department

• Ensures training is provided for firefighter/emergency response personnel to maintain proficiency in responding to hazardous material or hazardous waste incidents

• Responds to hazardous material or hazardous waste incidents in accordance with YPG Spill

Prevention Control and Countermeasures (SPCC) and the RCRA Contingency Plan

• Maintains technical library (i.e., Safety Data Sheets [SDSs], chemical hazards, etc.)

• Maintains installation wide hazardous material/hazardous waste inventory, as provided by the ESD.

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7.13 Preventative Medicine Office

The Preventative Medicine Office is not regulated by the YPG Garrison; however, they do work in conjunction with the ESD. The facility operates in accordance with AR 40-5, U.S. Army Medical Command Regulation 40-35, and other applicable federal, state, and local regulations.

The specific responsibilities of the Preventative Medicine Office are as follows:

• Serve as member of the EQCC (AR 200.1 [15-2.b])

• Provide for the disposal for non-RCRA medical, dental, and biomedical waste in accordance with AR 40-5, U.S. Army Medical Command Regulation 40-35, and federal, state, and local laws and regulations

• Provide the ESD with the solid waste and hazardous waste implications of new and revised medical practices for review and concurrence

• Prepare and maintain a management plan for the handling and disposal of biomedical waste

• Provide technical assistance in the identification of wastes created at the health and dental clinics.

7.14 Environmental Compliance Coordinators

The ECCs are specific facilities designated personnel responsible for the environmental compliance of a facility. The specific responsibilities of the ECCs are as follows.

• Attend semi-annual ECC meetings

• Understand and apply the YPG HWMP at their facility

• Ensure appropriate documentation is completed for all unit/activity environmental actions

• Ensure that all personnel handling hazardous material/hazardous waste are properly trained and training is documented

• Ensure personnel that are not trained are accompanied/observed during performance of all duties involving hazardous waste

• Ensure personnel comply with all federal, state, and local laws that pertain to the handling of hazardous material and hazardous waste

• Ensure the site is managed in compliance with all laws, regulations, and operating instructions, including Satellite Accumulation Points (SAPs)

• Ensure that all spill prevention and response procedures are followed in accordance with existing policies and regulations

• Ensure personal protection equipment (PPE) and spill kits are maintained at all work SAPs and/or work stations where hazardous material is present

• Coordinate turn-in of hazardous waste, including completing proper turn-in documentation

• Ensure the proper marking/labeling procedures are used on all hazardous waste containers

• Ensure the containers are kept closed except when being filled or emptied

• Accompany personnel on SAP inspections, maintain written records, and resolve discrepancies noted during inspections

• Maintain a record keeping system for copies of turn-in documents and training records

• Ensure all spills are properly reported.

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8. Spill Response YPG maintains a SPCC Plan to address the immediate actions to be taken in the event of a spill.

A Facility Emergency Response Plan is on file with ADEQ as part of requirements under EPCRA. A facility RCRA Contingency Plan is also maintained by YPG to address areas of concern. In the event of a hazardous waste spill, the following actions should be taken immediately:

• Cleanup will be completed by properly trained personnel with adequate PPE and spill response materials

• Immediately contain the spill if it can be done safely without causing injury

• Report the spill by referring to the SPCC.

YPG Health and Safety Personnel are Essential.

NO cleanup or sampling actions shall be performed unless workers are properly trained and have adequate PPE in addition to the proper spill response materials.

9. Hazardous Waste Identification Hazardous waste identification is an essential part of ensuring proper management and handling of waste. This section summarizes the process used by YPG for the identification of wastes.

Specific guidelines are available in the YPG Hazardous Waste Analysis Plan (see Appendix B).

9.1 Identification of Waste

At a minimum, when identifying if something is a hazardous waste, YPG utilizes a systematic approach that involves asking four questions, as indicated in 40 Code of Federal Regulations

(CFR) 262.11:

1. Is it a solid waste?

2. Is it exempt?

3. Is it listed?

4. Is it characteristic?

These determinations may be made using generator knowledge of the material and the processes generating the waste. Occasionally it is necessary to sample a waste to make an appropriate determination. If sampling is required for waste generated as a result of test activities, it may be given to the YPG Hazardous Waste Management Facility, along with a fund code, in an appropriate container where they can issue a Request for Lab Sampling. Wastes can also be sampled on site through coordination with the Hazardous Waste Manager. For assistance in determining wastes, the generator should contact the Hazardous Waste Manager.

9.2 Hazardous Waste Profiles

All hazardous waste streams at YPG must have a designated hazardous waste profile (HWP) within the current Hazardous Materials and Waste tracking database. Waste profiles are

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10. Hazardous Waste Management Facility YPG has a designated Hazardous Waste Management Facility, which is operated by personnel properly trained in the handling and management of hazardous materials and waste. The unique operations conducted at YPG make it unnecessary to warehouse large amounts of hazardous material. By only ordering as-needed materials, the potential for waste resulting from expired material is significantly reduced. It is the primary mission of the Hazardous Waste Management Facility to track all hazardous material and hazardous waste, monitor hazardous material use, assist in hazardous material reutilization, recommend improved efficiencies, and promote pollution prevention and hazardous material/hazardous waste minimization across the installation. Specific processes and procedures for the Hazardous Waste Management Facility are identified in the Hazardous Waste Management Facility SOP (Appendix C). YPG requires that all hazardous materials and waste, regardless of which unit, tenant, or operation orders or generates it, be tracked through the Hazardous Waste Management Facility.

11. Open Burn / Open Detonation Facility The Open Burn / Open Detonation (OB/OD) is a munitions treatment facility. The facility is used as a means for demilitarizing many explosive items, removing explosives from large metal objects, and reducing most combustibles to a smaller volume. The OB/OD is normally the safest method currently available for effective destruction, decontamination, and treatment of explosives and explosive waste. The facility is operated under a RCRA Part B permit (AZ5213830991) in accordance with the regulatory requirements of 40 CFR 264.

12. Hazardous Waste Accumulation and Storage The EPA and ADEQ strictly regulate hazardous waste accumulation and storage procedures.

Improper hazardous waste accumulation and storage deficiencies are among the most frequently cited hazardous waste violations. There are two options for accumulation and storage of hazardous waste at YPG: (1) SAPs and (2) a <90-day storage area.

12.1 Container Management

When accumulating and storing hazardous waste, it is important to exercise proper container management. The proper management of containers is an essential part of preventing accidental spills and releases of hazardous materials and waste. Accidental releases, which can occur due to improper container use, pose a risk to the health of YPG personnel and the surrounding environment. Below are the requirements and best management practices for proper container management.

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Labeling:

• A properly completed label or marking will be placed on all containers.

• Labels and markings will be replaced if they become illegible, damaged, or lost.

• Labels no longer applicable to the contents will be removed or painted over to make them unreadable. There will only be one (1) label on a container at any one time.

• Containers will be stored in such a manner so that labels are easily visible and should not have to be moved in order to read them.

Condition:

• Containers must be in adequate condition to hold the contents. If a container shows signs of bulging, pitting, cracking, rusting, and/or begins to leak, the contents will be transferred to a serviceable, approved container or over packed into a larger, non-leaking container.

Management and Handling:

• Containers shall remain closed except when adding or removing waste.

• Funnels and other fill devices must not be left in container openings.

• A container will not be opened, handled, or stored in a manner that may rupture the container or cause it to leak.

• Aisle space around each container or row of containers should be at least four (4) feet to allow unobstructed movement of personnel or the use of fire protection, spill control, and decontamination equipment.

• Containers will not be placed in rows more than two (2) containers wide or two (2) containers high so that all labels can be read.

• Closed-head (bunghole) type containers should be used to accumulate liquid materials or waste. Liquids and oil cannot be stored in open head drums.

• Open-top containers can be used to accumulate solid wastes (i.e., rags); however, rags contaminated with solvents must be kept in a tightly closed container due to the danger of spontaneous combustion. Additional information on solvent contaminated rags can be found in the YPG Rags and Wipes Policy (Appendix D).

• Containers used for storing waste will not be overfilled, leaving a minimum of six (6) inches of free space to allow for expansion/contraction due to temperature fluctuations.

• Hazardous waste containers should be placed on impervious surfaces (i.e., concrete or asphalt). Hazardous waste containers must not be placed on dirt, sand, grass, or gravel surfaces.

• Storage within a covered area or with any means of coverage is required to protect the area and containers from inclement weather conditions (i.e., rain).

Compatibility (see Section 12.1.1. – Container Compatibility):

• Incompatible wastes will not be placed in or within 10 feet of each other or must be separated by a wall or other type of structure.

• Containers will be compatible with the material they contain (see Table 12-1).

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Flammable/Reactive Waste:

• Containers storing ignitable or reactive wastes or materials must be located at least 50 feet from sources of ignition or spark-producing equipment and processes.

• "No Smoking" signs are required in these areas.

• These containers must also be located at least 50 feet from the installation boundary.

• Drums accumulating flammable wastes must be grounded when adding or removing waste.

12.1.1 Container Compatibility

Many materials, when mixed with other wastes or materials, can produce effects that are harmful to human health and the environment. These negative effects include: (1) heat or pressure,

(2) fire or explosion, (3) violent reaction, (4) toxic dust, mists, fumes, or gases, or (5) flammable fumes or gases. Incompatible wastes must never be stored in the same container. Containers holding wastes must be separated or protected from other stored incompatible wastes by means of a wall, berm, or other device adequate to prevent the mixing of the incompatible wastes.

Appendix E contains a material compatibility chart to assist in determining waste and compatibility. Wastes must also be stored in a compatible container, as various reactions can also happen when waste is placed in an inappropriate container. Table 12-1 lists the container compatibility for certain materials that may be encountered at YPG.

Table 12-1: Container Compatibility Chart

Material Steel Stainless Steel Polyethylene Acetic Acid N Y Y Acetone Y Y Y Aniline N Y Y Benzene N Y Y

MEK Y Y Y

Butylene Y Y N Chlorofluorocarbons N Y N Cyclohexane Y N N Ethanol Y Y Y Ethyl Acetate N Y Y Ethyl Ether Y Y N Ethylene Glycol N Y Y Fuel Oil Y Y Y Gasoline Y Y Y Heptane Y Y Y Hexane Y Y Y Kerosene or JP-8 Y Y Y Methanol Y Y Y Methylene Chloride N Y N

FOR OFFICIAL USE ONLY

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Material Steel Stainless Steel Polyethylene Petroleum Ether Y Y N Toluene Y Y Y Trichloroethylene N Y N Xylene Y Y Y

FOR OFFICIAL USE ONLY

14 February 2018

12.2 Hazardous Waste Management Facility Disposition Bins

Facilities commonly using hazardous materials shall utilize ‘Hazardous Materials Disposition” bins. Bins are 55-gallon metal cans with a lid, and are labeled as ‘Hazardous Waste Management Facility Disposition.’ These bins are intended for the accumulation of depleted hazardous material containers. The contents of the bins are collected on a weekly basis or as needed by the Hazardous Waste Management Facility. The materials located within the Hazardous Waste Management Facility disposition bins are not designated as waste until the Hazardous Waste Manager or other Hazardous Waste Management Facility personnel determine they are wastes.

These personnel are responsible for determining the appropriate disposition of these depleted material containers.

12.3 Satellite Accumulation Point

YPG has several SAPs throughout the installation (see Appendix F, Satellite Accumulation Point Plan). The SAPs are the initial accumulation point of hazardous waste and are used to increase the efficiency of waste collection and to reduce the cost of its disposal. All YPG SAPs are established in accordance with 40 CFR 262.34(c)(1) and the SAP Plan. The SAPs are only utilized to collect and store the hazardous waste generated at or near that specific SAP. At no time can more than 55 gallons be present in a single SAP. The policy at YPG is that containers must be turned in to the Hazardous Waste Management Facility at 75% capacity to allow for heat expansion.

The SAP facility building number and the specific SAP waste identified may be found in the SAP Plan provided in Appendix F.

12.4 <90-Day Storage Site YPG has one <90-day storage site that is operated by the YPG Hazardous Waste Management Facility. The <90-day hazardous waste storage site is a fenced and locked yard with a concrete structure located behind Building 2075. This facility is capable of safely storing the hazardous waste generated at YPG. Included in the 90-day yard is a covered 1,500-square foot concrete structure that is divided into six bays. Each bay provides storage for different classifications of solid and hazardous wastes. This division ensures that incompatible wastes are not stored together.

The bay is sloped towards the center which prevents accidental spills or leaks from discharging.

The open area of the yard provides adequate space for roll-off bins containing petroleum contaminated soil (PCS). General requirements for the <90-day storage facility include a fenced and locked yard, fire extinguisher, means of communication, and spill kit compatible for each type of hazardous waste.

12.5 Site Requirements

Hazardous waste storage areas are located in such a way that accidental spills and discharges do not flow into sanitary sewers or storm water runoff systems. Storage areas are located on concrete, asphalt, or other material that is impervious to leaks and spills.

12.6 Quantity and Time Limitations

There are no quantity limits for 90-day storage sites. At YPG, hazardous waste may be stored for up to 90 days without a state-issued permit. The 90-day count begins from the oldest accumulation start date, as written on the container’s hazardous waste label.

15 February 2018

12.7 Required Facility Signage

In order to maintain the safety of personnel and proper management of hazardous waste, certain signage should be present at accumulation and storage sites. These signs include:

• ‘No Smoking’

• Sign indicating the location of the ‘Fire Extinguisher’

• Sign indicating the location of the ‘Spill Kit.’

12.8 Facility Inspections

Inspections are conducted regularly at all SAP sites and the <90-day storage yard. Inspections are conducted by designated and trained personnel to ensure compliance with RCRA regulations.

12.9 Secondary Containment

Secondary containment is required for storage areas where there is a possibility for spills to enter the environment and cause harm. Secondary containment must be capable of holding the contents of the largest stored container, plus freeboard space of approximately 3-½ inches when outside to allow for rainwater. Secondary containment must be kept free of any liquids or soil to maintain adequate containment space. Secondary containment is inspected during regular facility inspections; however, facility personnel should not depend on these inspections alone to identify potential problems. Facility personnel are responsible for ensuring they have proper secondary containment where needed.

13. Hazardous Waste Handling Overview YPG is concerned with the health and safety of its personnel and the environment and recognizes that properly handling hazardous waste is essential. Good inventory management practices, such as using older product before new product, checking expiration dates, purchasing only what is required for the mission, and using/purchasing a less hazardous or non-hazardous material, are ways to reduce hazardous waste generation and disposal costs. The cost of hazardous waste disposal can be >10 times the original purchase price of the material. Facilities that generate a hazardous waste must include disposal and characterization costs for waste in their budgets.

13.1 Known Wastes

Wastes that are known to be hazardous are handled in accordance with the material’s SDS and applicable federal, state, and local regulations. Proper containers and labeling must be used for hazardous waste and managed in accordance with Section 12.1 of this HWMP. All hazardous waste must be disposed of through the Hazardous Waste Management Facility. Known wastes accumulated in a designated SAP shall be managed in accordance with the SAP Plan (Appendix F).

13.2 Commonly Overlooked Wastes

Some hazardous wastes are easily identifiable and recognized as hazardous by both facility and material knowledge or by visible product labeling. However, there are many hazardous wastes that are commonly overlooked and therefore not managed properly.

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13.2.1 Shop Rags

Many routine maintenance activities at YPG result in the generation of wipes and clean up materials that may become contaminated with solvents and other products or wastes that are regulated. Shop rags and clean up materials (i.e., absorbents, socks, and booms) that are contaminated with grease, oil, or solvents should be managed according to the YPG guidance specific to Quick Guide – Rags and Wipes (Appendix D). Used rags are to be stored in a clearly labeled metal container with a cover that is away from all ignition sources. If solvent-contaminated shop rags are not hazardous waste, they may be bagged and disposed of as a non-hazardous solid waste. Additional guidance related to management of solvent-contaminated rags is provided in Appendix D.

13.2.2 Aerosol Cans

Aerosol cans are considered a hazardous material/hazardous waste because the contents are under pressure. The propellants used in aerosol cans may be considered an EPA D001 ignitable or D003 reactive waste. All hazardous material must be tracked from “cradle-to-grave” by the Hazardous Waste Management Facility in an Army-wide database. All aerosol cans that are empty, have become clogged, are expired, or are otherwise unserviceable must be turned in to the Hazardous Waste Management Facility for puncturing, draining, and recycling of the metal can.

For facilities containing a Hazardous Waste Management Facility disposition bin (see Section 12.2), empty aerosol cans may be placed in the bin for pick-up. For facilities that do not have a Hazardous Waste Management Facility disposition bin, or for aerosols that are not empty, the aerosols must be delivered to the Hazardous Waste Management Facility for turn-in.

13.2.3 Flameless Ration Heaters

Meals ready-to-eat come with a heating unit, called a flameless ration heater (FRH), that contains a small amount of elemental magnesium. When this magnesium comes into contact with water, it causes a chemical reaction that gives off heat. Unused FRHs are therefore considered reactive and when disposed of, they must be properly managed as a D003 reactive hazardous waste.

Unused FRHs cannot be activated at locations other than the area of use in order to decrease the amount of waste generated because these actions may be considered waste treatment by environmental regulators. All excess FRHs must be turned-in to the Hazardous Waste Management Facility for proper disposal.

13.2.4 Munitions

Spent military munitions are managed under RCRA by the Military Munitions Rule that allows for the recovery of recyclable materials that have been rendered safe by qualified personnel. All munitions for the training ranges are issued by and turned-in through the Ammunition Management Office at Building 3294 for proper management and disposal. Range residues (i.e., ammunition boxes, pallets, clips, and small arms brass) will be collected and returned to the Ammunition Management Office on completion of training for reconciliation and disposition.

FOR OFFICIAL USE ONLY

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13.2.5 Parts Washers

Parts washers are located throughout the installation where vehicle and weapons maintenance activities occur. They are used to remove dirt, oil, and grease from various types of small parts using petroleum-based cleaning solvents, water-based cleaning solvents, or hot water. The types of parts washers and how they are used generate different types of waste. Spent solvents, used filters, and sludge are common wastes generated from parts washers. The majority of parts washers at YPG are maintained by a contract with Safety-Kleen®, including the wastes they generate. Parts washers not contracted with Safety-Kleen® require that generated waste be disposed of through the Hazardous Waste Management Facility and generally require sampling to determine its specific contaminant(s), as it may vary depending on the cleaning solution used and the parts washed.

13.3 Unknown/Abandoned Wastes

Due to YPG’s large size, remote location, and historic uses, it is possible for personnel to occasionally encounter unidentified containers. If an unknown container is located, it is essential that it is not touched or opened.

ALL UNKNOWN OR ABANDONED CONTAINERS MUST BE HANDLED WITH

CAUTION!!! DO NOT ASSUME THAT A LABEL ACCURATELY REFLECTS THE

CONTENT OF THE CONTAINER!

Upon discovery of an unknown or abandoned container, immediately call the YPG Fire Department, or contact Range Control if found on the firing ranges. Provide as much information to the responders as possible without endangering yourself or others.

13.4 Waste Turn-In

All waste turn-ins are handled in accordance with DPAM 710-7. Waste turn-ins should be taken to the Hazardous Waste Management Facility within 3 days by coordinating with the Hazardous Waste Manager or the Hazardous Waste Management Facility. To turn-in hazardous waste, the generator should follow the steps listed below:

1. Ensure the container is packaged, marked, and labeled. SAP wastes should be handled in accordance with the SAP Plan.

2. Complete a turn-in document, Form 1348-6, along with an active funding code.

3. If the type of material that generated the waste is known, then an SDS should be provided.

4. If the waste requires analysis to determine the level or type of hazard, the Hazardous

Waste Manager should be notified and the container should be labeled as “HAZARDOUS

WASTE PENDING ANALYSIS.”

The Hazardous Waste Management Facility operates under its own SOP as part of the DOL and is subject to change. These changes may cause a change in the forms and other requirements for waste turn-in. It is the responsibility of the DOL to ensure that YPG personnel are aware of these changes. For additional information regarding the turn-in of a hazardous waste, the generator should contact the Hazardous Waste Manager or the Hazardous Waste Management Facility personnel.

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13.5 Universal Waste

The universal waste program in RCRA, Part 273, allows five types of wastes to be managed differently than other hazardous wastes, as follows:

• Used batteries

• Recalled pesticides

• Mercury containing items

• Mercury-containing lamps

• Cathode ray tubes.

Arizona adopted the universal waste rules in 2001. This reduction in regulation results in less liability and lowers the cost of disposal for all units/activities at YPG. YPG manages universal waste through the ESD “Universal Waste Management Plan” (see Appendix A). All universal waste is managed through the Hazardous Waste Management Facility.

14. Non-RCRA Regulated…