TE 5 - Hazardous Waste Management Plan (HWMP).pdf

HAZARDOUS WASTE MANAGEMENT PLAN

Department of the Army Headquarters, 10th Mountain Division

Public Works, Environmental Division

Fort Drum, New York

Revised Jul 2025

FORT DRUM ENVIRONMENTAL COMMITMENT

Although the primary mission of the United States Army is national defense, Fort Drum is also committed to protecting our environment and conserving our natural resource heritage for present and future generations. To ensure fulfillment of Fort Drum’s commitment, the Army has adopted the following environmental goals:

• Demonstrate leadership in environmental protection and improvement;

• Minimize adverse environmental and health impacts while maximizing readiness and strategic preparedness;

• Ensure that consideration of the environment is an integral part of Army decision-making;

• Initiate aggressive action to comply with all federal, state, and local environmental quality laws;

• Restore lands and waters damaged through our past waste disposal practices;

• Support Army programs for recycling and reusing materials to conserve natural resources, prevent pollution, and minimize generation of wastes; and,

• Pursue an active role in addressing environmental quality issues in our relations with neighboring communities.

HAZARDOUS WASTE MANAGEMENT PLAN

FORT DRUM, NEW YORK

This Fort Drum Hazardous Waste Management Plan meets the requirements of AR 200- 1, Environmental Protection and Enhancement, dated 13 Dec 07, and 40 Code of Federal Regulations (CFR) 264.52, minimizing hazards to human health and the environment caused by potentially hazardous waste spills.

This Hazardous Waste Management Plan was prepared by the Fort Drum, Public Works, and Environmental Hazardous Waste Program Manager.

Hazardous Waste Management Plan Approving Officials:

Signature: _________________________________ DATE: _______________

IAN G. CRAWFORD

CHIEF, COMPLIANCE BRANCH

JAMES M. MILLER

CHIEF, ENVIRONMENTAL DIVISION

Hazardous Waste Management Plan Approving Authority:

KURT W. HAUK

DIRECTOR, PUBLIC WORKS

TABLE OF CONTENTS

PAGE

ACRONYMS AND ABBREVIATIONS V

SECTION 1: INTRODUCTION

1-1

1.1 PURPOSE AND SCOPE 1-1

1.2 APPLICABILITY 1-1

1.3 PLAN OVERVIEW 1-2

SECTION 2: ENVIRONMENTAL CONTACTS AND PHONE NUMBERS

2-1

2.1 PUBLIC WORKS ENVIRONMENTAL DIVISION CONTACTS 2-1

SECTION 3: HAZARDOUS WASTE REGULATIONS

3-1

3.1 HAZARDOUS WASTE REGULATIONS AND TABLE 3-2

3.2 FORT DRUM REGULATORY STATUS 3-3

3.3 HAZARDOUS WASTE GENERATED 3-3 – 3-4

3.4 HAZARDOUS WASTE MANAGEMENT RESPONSIBILITIES 3-4 – 3-5

3.5 ENVIRONMENTAL DIVISION “YOU CALL – WE HAUL” SERVICE 3-5 – 3-6

3.6 CONTRACTOR GENERATED HAZARDOUS WASTE

MANAGEMENT AND DISPOSAL REQUIREMENTS

3-6 – 3-7

3.7 HAZARDOUS MATERIALS CONTROL CENTER 3-7

3.8 HAZARDOUS WASTE ANALYSIS 3-7

3.8.1 SAMPLING FREQUENCY 3-7 – 3-8

3.8.2 HAZARDOUS CHARACTERISTICS ANALYSIS 3-8

SECTION 4: HAZARDOUS WASTE MANAGEMENT REQUIREMENTS

4-1

4.1 STANDARD OPERATING PROCEDURES 4-1 – 4-4

4.2 HAZARDOUS WASTE CONTAINER REQUIREMENTS 4-4 – 4-5

4.3 HAZARDOUS WASTE CONTAINER LABELING 4-5 – 4-6

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TABLE OF CONTENTS (Continued)

PAGE

4.3.1 SATELLITE ACCUMULATION AREA CONTAINERS 4-6

4.3.2 LESS-THAN-90-DAY ACCUMULATION FACILITY

CONTAINERS

4-6 – 4-7

4.4 HAZARDOUS WASTE ACCUMULATION TIME AND VOLUME

LIMITS

4-7

4.4.1 SATELLITE ACCUMULATION AREA 4-7 – 4-8

4.4 2 LESS-THAN-90-DAY ACCUMULATION FACILITY 4-8

4.5 HAZARDOUS WASTE ACCUMLATION AREA INSPECTION 4-8 – 4-9

4.6 OFF-SPECIFICATION, OUTDATED, AND EXCESS HAZARDOUS

MATERIAL TURN/-IN/DISPOSAL

4-9

4.7 ITEMS REQUIRING DEMILITARIZING 4-9

4.8 AMMUNITION AND EXPLOSIVE (AE) AND RESIDUE 4-9

SECTION 5: UNIVERSAL WASTE MANAGEMENT

5-1

5.1 DEFINITION 5-1

5.2 PROPER MANAGEMENT OF UNIVERSAL WASTE 5-1

5.2.1 FLUORESCENT LIGHT TUBES AND HIGH INTENSITY

DISCHARGE LAMPS

5-1 – 5-2

5.2.2 LITHIUM, NICAD, MAGNESIUM AND MERCURY BATTERIES 5-2

5.2.3 RECHARGEABLE BATTERIES

5.3 UNIVERSAL WASTE LABELING REQUIREMENTS

5.4 UNIVERSAL WASTE SPILL PROCEDURES

5.4.1 MERCURY CONTAINING FLUORESCENT LAMPS

5.4.2 MERCURY THERMOSTATS

5.4.3 DISCHARGED OR VENTING LITHIUM BATTERIES

5.4.4 BROKEN LEAD ACID BATTERIES

5.5 UNIVERSAL WASTE REQUIREMENTS FOR CONTRACTORS

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5-2 – 5-3

5-3

5-3

5-3 – 5-4

5-4

5-4

5-4 – 5-5

5-5

5.5.1 UNIVERSAL WASTE LAMPS

5.5.2 UNIVERSAL WASTE MERCURY THERMOSTATS

SECTION 6: MISCELLANEOUS WASTE

5-5 – 5-6

6-1

6.1 PROPER DISPOSAL OR RECYCLING OF EMPTY CONTAINERS 6-1

6.1.1 FOR CONTAINERS THAT PREVIOUSLY OR STILL CONTAIN

LIQUIDS

6.1.2 FOR CONTAINERS THAT PREVIOUSLY OR STILL CONTAIN

SOLIDS

6.2 HOUSEHOLD HAZARDOUS WASTE

6.3 ALKALINE BATTERIES

6-2

6-2

6.4 DENTAL AMALGAM WASTE 6-2

6.4.1 DISPOSAL OF DENTAL AMALGAM WASTE 6-2 – 6-3

SECTION 7: OIL AND HAZARDOUS SUBSTANCE SPILL AND

CONTINGENCY PLAN

7-1

7.1 REGULATORY REQUIREMENTS 7-1

7.2 DESCRIPTION OF PLAN 7-1 – 7-3

7.3 SPILL RESPONSE NOTIFICATION PROCEDURE 7-3

7.4 INFORMATION TO BE REPORTED 7-3

SECTION 8: HAZARDOUS WASTE EMPLOYEES TRAINING PLAN

8-1

8.1 INTRODUCTION 8-1

8.2 PART 1: TRAINING COURSE DESCRIPTIONS 8-1

8.2.1 DEFENSE HAZARDOUS MATERIALS/WASTE HANDLING

INITIAL COURSE

8-1 – 8-2

8.2.2 DEFENSE HAZARDOUS MATERIALS/WASTE REFRESHER

COURSE

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8-2

8.2.3 HAZARDOUS WASTE PROGRAM MANAGER COURSE 8-3

8.2.4 HAZARDOUS WASTE OPERATIONS AND EMERGENCY

RESPONSE TRAINING

8.2.5 ENVIRONMENTAL OFFICER (EO) COURSE

8.2.6 HAZARD COMMUNICATION STANDARD TRAINING

8-3 – 8-4

8-4

8-5

8.2.7 HAZARDOUS WASTE DOT/MANIFEST CERTIFICATION

INITIAL COURSE

8-5

8.2.8 HAZARDOUS WASTE DOT/MANIFEST RECERTIFICATION 8-6

8.2.9 FIRST RESPONDERS TRAINING 8-6

8.3 PART 2: PERSONNEL TRAINING REQUIREMENTS 8-6

8.3.1 SITE: BUILDING 11144, ENVIRONMENTAL DIVISION

HAZARDOUS WASTE CENTRAL ACCUMULATION FACILITY

8-6 – 8-8

8.3.2 SITE: BUILDING 2040/2050/2070/2072/2074/2060/19710

AIRCRAFT MAINT FACILITIES

8.3.3 SITE: BUILDING P-10345 INDOOR RANGE 2

8-8 – 8-9

8-9

8.3.4 WASTE DENTAL AMAGLAM REQUIRED TRAINING 8-9

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ACRONYMS AND ABBREVIATIONS

AR ARMY REGULATION

AUL AUTHORIZED USE LIST

CFR CODE OF FEDERAL REGULATIONS

CSO COMMAND SAFETY OFFICE

ENV DIV ENVIRONMENTAL DIVISION

EQCC ENVIRONMENTAL QUALITY CONTROL COUNCIL

HM HAZARDOUS MATERIAL

HMCC HAZARDOUS MATERIAL CONTROL CENTER

HSMS HAZARDOUS SUBSTANCE MANAGEMENT SYSTEM

HWMP HAZARDOUS WASTE MANAGEMENT PLAN

HWRP HAZARDOUS WASTE REDUCTION PLAN

NYCRR NEW YORK CODES, RULES, AND REGULATIONS

NYSDEC NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL

CONSERVATION

PCB POLYCHLORINATED BIPHENYL

POC POINT OF CONTACT

PVC POLYVINYL CHLORIDE

PW PUBLIC WORKS

RCRA RESOURCE CONSERVATION AND RECOVERY ACT

SAA SATELLITE ACCUMULATION AREA

SDS SAFETY DATA SHEET

SOP STANDARD OPERATING PROCEDURE

SPCC SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN

UBL UNIT BASIC LOAD

USEPA U.S. ENVIRONMENTAL PROTECTION AGENCY

SECTION 1

INTRODUCTION

1.1 PURPOSE AND SCOPE

The purpose of this Hazardous Waste Management Plan (HWMP) is to state the objectives and policies of the 10th Mountain Division and Fort Drum regarding the management of hazardous waste and to provide operating procedures designed to comply with these policies and objectives. The objectives of this guide are to:

• Present policies and procedures that satisfy the requirements of all applicable Federal, State, Department of Defense, and Fort Drum regulations;

• Present policies and procedures that are consistent with Fort Drum's Hazardous

Waste Reduction Plan (HWRP) and the Spill Prevention, Control, and Countermeasures (SPCC) Plan;

• Promote post-wide awareness of the procedures required for proper hazardous waste management;

• Establish a common understanding between Fort Drum and environmental regulatory agencies regarding the hazardous waste management policies and procedures followed at Fort Drum.

Army Regulation (AR) 200-1, Environmental Protection and Enhancement, dated 13 Dec 07 requires a formal HWMP. Careful planning is required to ensure proper hazardous waste management. Planning elements are specified in Chapter 5, of the Department of Army Pamphlet (DA Pam) 200-1.

1.2 APPLICABILITY

This plan is provided for all personnel who generate, handle, and/or store Resource Conservation and Recovery Act (RCRA) hazardous waste and/or universal waste at Fort Drum. A copy of this HWMP must be kept and complied with at all potentially hazardous waste spill sites, satellite hazardous/universal waste accumulation points, and less-than-90-day accumulation areas. This plan is applicable to 10th Mountain Division, Fort Drum Garrison, Fort Drum Tenant Units/Activities, Contractor Activities, and any other activities or person on the installation. In addition to delineating the policies and procedures for the management of hazardous waste and/or universal waste, Section 7, of this plan outlines the emergency response procedures for hazardous substance spills, just as the SPCC Plan outlines the emergency response procedures for all oil products stored and in-use at Fort Drum.

This plan does not address radioactive waste. Questions regarding radioactive waste should be directed to the Radiological Protection Officer of the Fort Drum Command Safety Office (CSO), 772-5352.

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1.3 PLAN OVERVIEW

This plan is divided into eight sections. A listing of each section title, followed by a brief description of that section's main objective, is provided below.

Section 1 – Introduction: Provides information on the purpose of this plan, the facility to which it applies, and environmental regulatory requirements.

Section 2 – Environmental Contacts and Phone Numbers: Lists sources of help with interpretation of hazardous waste management policies.

Section 3 – Hazardous Waste Regulations: Provides a brief summary of environmental regulations that impact the management of hazardous waste. This section also identifies Fort Drum’s regulatory status; types of hazardous waste generated; hazardous waste management responsibilities; and procedures for sampling and analysis of hazardous waste streams prior to disposal.

Section 4 – Hazardous Waste Management Requirements: Summarizes activities associated with the management of hazardous waste at accumulation points/areas

Section 5 – Universal Waste Management: Provides information on the proper management of Universal Wastes concerning fluorescent light tubes, high-pressure sodium vapor, high intensity discharge, or mercury vapor lamps, Lithium and Nickel Cadmium (NICAD) batteries, and mercury containing thermostats.

Section 6 – Miscellaneous Waste: Provides information on the proper disposal of empty containers. Provides information concerning household hazardous waste from Mountain Community Homes and Single Soldier Barracks. Also covers proper management of used alkaline batteries, and dental amalgam waste.

Section 7 – Oil and Hazardous Substance Spill and Contingency Plan:

Summarizes Fort Drum’s policies and procedures for hazardous waste spill response and references the Spill Prevention, Control and Countermeasures Plan for oil spill response and other applicable spill contingency plans.

Section 8 – Hazardous Waste Employee Training Plan: Presents an outline of applicable training that is conducted at Fort Drum.

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SECTION 2

FORT DRUM ENVIRONMENTAL CONTACTS

AND PHONE NUMBERS

2.1 PUBLIC WORKS ENVIRONMENTAL DIVISION, COMPLIANCE BRANCH

CONTACTS:

The Public Works Environmental Division, Compliance Branch, building 4000, is responsible for coordinating and managing Hazardous Waste and Universal Waste activities at Fort Drum. The phone numbers for key personnel are presented below.

Contacts Office Number Cellular Number

Chief, Environmental Division 315-772-5269 315-921-4018

Compliance Branch Chief 315-772-5063 315-523-1497

Hazardous Waste Program Manager 315-772-4156 315-777-3434

Hazardous Waste Program Assistant 315-772-9408 N/A

“You Call – We Haul” Service 315-772-6111 N/A

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SECTION 3

HAZARDOUS WASTE REGULATIONS

3.1 HAZARDOUS WASTE REGULATIONS

Environmental laws provide a mandate to federal government agencies, such as the U.S. Environmental Protection Agency (USEPA), to develop a program for addressing adverse incidents or situations, such as the uncontrolled release of hazardous waste into the environment. Most environmental laws are conceptual and do not provide specific details on achieving the stated goals. Thus, enforceable regulations are drafted by the empowered government agencies, such as the state or local environmental protection agency. These regulations usually contain detailed performance specifications describing how to comply with the law.

Many laws created at the federal level allow individual state governments to assume authority for an environmental program and to create their own laws and regulations.

States often create their own environmental regulations based on the federal model with some state-specific variations. As long as the state regulation is at least as protective of human health and the environment as the federal version, the state regulation becomes the established code to which the regulated community must comply. Otherwise, federal requirements must be met.

The Department of the Army also has its own environmental regulations, which require compliance with all applicable federal and state regulations, plus execution of special Army programs. In addition, local communities may have applicable regulations as to how their municipal facilities, such as landfills and wastewater treatment plants, are to be used.

The following table lists several environmental regulations applicable to hazardous waste management at Fort Drum. This section is not inclusive of all environmental regulations; rather it is a summary of pertinent federal and state regulations provided to give the reader a brief overview of regulations applicable to hazardous waste management at Fort Drum. Specific regulations applicable to transportation, spills, disposal, and storage containers, etc., may be contained within the regulations below or identified in other Fort Drum plans including the HWRP and the SPCC.

3-1

REGULATION DESCRIPTION APPLICABILITY

Resource Conservation and Recovery Act (RCRA)

Establishes framework for managing hazardous waste

Handling of hazardous waste.

6 NYCRR Part 370 http://www.dec.ny.gov/regs/4390.html

Hazardous Waste Management System – General

Provides definitions of terms and general standards for Parts 370-

6 NYCRR Part 371 http://www.dec.ny.gov/regs/14897.html

Identification and listing of hazardous waste.

Establishes procedures for solid wastes which are subject to regulations 370 – 376

6 NYCRR Part 372 http://www.dec.ny.gov/regs/4388.html

Hazardous Waste Management System and Related Standards for Generators, Transporters and Facilities

Establishes standards for hazardous waste generators relating to the use of the manifest system and its recordkeeping requirements.

6 NYCRR Part 373-1 http://www.dec.ny.gov/regs/14921.html

Hazardous Waste Treatment, Storage and Disposal Facility Permitting Requirements

Establishes permitting requirements for owners and operators of hazardous waste, treatment, storage and disposal facilities.

6 NYCRR Part 373-1 http://www.dec.ny.gov/regs/14937.html

Final Status Standards for Owners and Operators of Hazardous Waste Treatment, Storage and Disposal Facilities

Establishes minimum State standards defining acceptable management of hazardous waste for owners or operators of all facilities which treat, store, or dispose of hazardous waste.

6 NYCRR Part 374-2 http://www.dec.ny.gov/regs/4379.html

Standards for the Management of Used Oil

Identifies materials which are subject to regulation as used oil IAW 374-2.2 or those materials subject to regulation as hazardous waste under Parts 370-374-1 and 376.

6 NYCRR Part 374-3 http://www.dec.ny.gov/regs/4378.html

Standards for Universal Waste

Establishes requirements for managing batteries and fluorescent lamps as an alternative to regulation Parts 370-374-1 and 376.

6 NYCRR Part 374-4 http://www.dec.ny.gov/regs/4377.html

Standards for the Management of Elemental Mercury and Dental Amalgam Wastes

Establishes requirements for dental facilities for the proper management of dental amalgam waste through recycling.

6 NYCRR Part 376 http://www.dec.ny.gov/regs/4369.html

Land Disposal Restrictions Identifies hazardous wastes restricted from land disposal and defines those limited circumstances under which an otherwise prohibited waste may be land disposed.

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3.2 FORT DRUM REGULATORY STATUS

The regulations developed by the USEPA pertaining to RCRA are contained within Title 40 of the CFR Parts 260 through 282. In particular, the requirements for hazardous waste generators are contained within 40 CFR 260, 261 and 262. Information contained in these subparts contains, but is not limited to, details regarding generation and disposal of hazardous waste, appropriate documentation, reporting requirements, and volume/time limitations.

Every generator of RCRA hazardous waste must have an EPA identification number and must use that number to participate in the hazardous waste manifest system. For the purpose of disposing of hazardous waste off-post, all waste-generating activities at Fort Drum, except for biomedical wastes, are covered by a single Fort Drum EPA Generator ID number (NY0214020281).

Fort Drum generates hazardous waste as a result of training and readiness activities.

According to EPA’s categories for hazardous waste generators, Fort Drum is classified as a large quantity hazardous waste generator since more than 1,000 kilograms (or 1.1 tons) of hazardous waste is expected to be generated in any given month. In addition, large quantity generators are limited to the generation of 1 kilogram per month of acute hazardous waste; however, Fort Drum rarely, if ever, generates this type of waste.

As a large quantity generator, there is no limit to the quantity of waste generated.

However, a time restriction on the waste requires that it be disposed of within 90 days of placing the waste into the storage container. If the installation opts to ‘satellite’ the waste first, the waste must be collected in a container at or near the point of generation.

This area, referred to as a satellite accumulation area, is regulated by a volume limit of 55 gallons or one quart of acute waste. When this quantity has been reached, the waste must be transported to the on-post less-than-90-day waste facility, Building P- 11144.

Since hazardous wastes are stored on-site for less-than-90 days, Fort Drum is not a RCRA Part B permitted hazardous waste storage facility. All waste is manifested and sent to an offsite Treatment, Storage, and Disposal Facility (TSDF) or sent to an approved designated facility (i.e., recycling) for disposal. In addition, signed manifests are kept on record for at least three years from the date of shipment.

3.3 HAZARDOUS WASTE GENERATED

Hazardous wastes at Fort Drum are generated from vehicle maintenance activities, medical treatment, chemical defense training, and installation facility management activities. Used oil, used antifreeze, and off-spec fuel are not considered hazardous

3-3 wastes; and hazardous waste rules do not apply to these waste streams unless they are mixed with a regulated hazardous waste, such as organic solvents.

3.4 HAZARDOUS WASTE MANAGEMENT RESPONSIBILITIES

In accordance with AR 200-1, Environmental Protection and Enhancement, dated 13 Dec 07, the Installation Commander has overall responsibility for management of hazardous materials and hazardous wastes. The following guidelines will be followed to ensure implementation of this Hazardous Waste Management Plan:

• Fort Drum shall maintain records which account for all hazardous waste from cradle to grave using an automated tracking system;

• All levels of command will continually seek specialized training for their personnel who handle, transport, and/or store hazardous waste. This training shall be reinforced by way of effective supervision;

• Efficient use of hazardous materials and proper handling and disposal of hazardous waste shall be of prime concern to all personnel;

• Storing and handling hazardous waste shall be accomplished in compliance with all applicable regulatory requirements to prevent adverse effects on human health and the environment;

• All hazardous materials will be procured through the Hazardous Management Control Center (HMCC), IAW their AUL; and

• The use of non-hazardous materials as substitutes for hazardous materials will be promoted throughout Fort Drum.

The Fort Drum Environmental Quality Control Council (EQCC) was established to provide assistance to the Garrison Commander in formulating policies and plans for the protection, preservation, and enhancement of the environment. Members of the council represent operational, engineering, planning, resource management, legal, medical, and safety interests of the command, including military installation tenant activities. This council is an integral part of Fort Drum's environmental program that is intended to minimize impacts on the quality of the environment without impairing the overall mission. The EQCC also serves as an informal forum for managing hazardous waste issues. Authority for the EQCC comes from AR 200-1, Environmental Protection and Enhancement, dated 13 Dec 07, paragraph 12-13; AR 420-17, Real Property and Resource Management, paragraph 6-6; and US Army Forces Command Supplement 1 to AR 200-1, paragraph 2-6.

The EQCC is made up of the following individuals, offices, and agencies:

• Fort Drum Garrison Commander; EQCC Chair

• Deputy to the Garrison Commander;

• Garrison Command Sergeant Major

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• Division Brigade Executive Officers;

• Staff Judge Advocate;

• Commander, Medical Department Activity;

• Director, Army Field Support Battalion (AFSBN);

• Director, Directorate of Plans, Training, Mobilization, and Security;

• Director, DES;

• Director, DOC;

• Director, DRM IMA;

• Director, Safety Office;

• General Manager, AAFES;

• Director, Public Works

• Public Works, Environmental Division Chief;

It is the responsibility of the Fort Drum activities generating hazardous waste to handle their waste safely and to make timely arrangements for pick-up and disposal by calling the Public Works Environmental Division, Hazardous Waste Program, “You Call – We Haul” pick-up service line at 772-6111. In addition, designated officials and agencies have other specific responsibilities for execution of the Fort Drum Hazardous Waste Management Plan.

3.5 ENVIRONMENTAL DIVISION “YOU CALL – WE HAUL” SERVICE

The Fort Drum Public Works Environmental Division, Hazardous Waste Program provides a “You Call - We Haul” service to installation activities generating wastes, expired latex paints, waxes, non-hazardous liquids, and unused or unwanted hazardous materials. When a generator requires pick-up of these materials, they must call the Hazardous Waste Program, “You Call - We Haul” pick-up service line at 772-6111. The Environmental Division Hazardous Waste Personnel and the generating activity will then coordinate a time for pick-up. Installation activities are not authorized to collect any of these wastes without prior approval from the Hazardous Waste Program Manager.

Types of waste typically generated requiring pick-up are paints, aerosol cans (even empty), adhesives, floor wax, alcohols, grease, M9/M8 paper, C2 canisters, disinfectants, insecticides, batteries (NON-LEAD ACID), and fluorescent light tubes.

Generators are asked to call if they are not sure if what they have is hazardous or not.

A Safety Data Sheet (SDS) is required for all wastes turned in. No aerosol cans are allowed to be disposed of in solid waste dumpsters, empty or not. A container for EMPTY aerosols is issued by the Environmental Division Hazardous Waste Personnel upon request. Empty aerosols must be collected with nozzles and caps on. When the container is full the generator must call the “You Call – We Haul” service number at 772- 6111, for pick-up. Aerosol depressurizing is only authorized by the Fort Drum Public Works Environmental Division, Hazardous Waste Personnel.

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All aerosols which are not empty must be kept in a flammable locker. If the generator has no use for aerosols with product, they should call the Hazardous Material Control Center (HMCC) at 772-5250, to coordinate returning them. Generators with aerosols containing product, but no propellant, or have clogged nozzles, will place them in a flammable locker and immediately call the “You Call – We Haul” service at 772-6111, to coordinate pick-up. DO NOT PUT THESE AEROSOLS IN THE CONTAINER FOR EMPTY AEROSOLS! These aerosol cans are considered hazardous waste and must be managed as such.

The local landfill doesn’t accept ANY liquids; therefore, ALL non-hazardous waste liquids are to be absorbed prior to disposing in dumpsters. If this cannot be accomplished, call the “You Call – We Haul” service, at 772-6111, to coordinate pick-up.

3.6 CONTRACTOR GENERATED HAZARDOUS WASTE MANAGEMENT AND

DISPOSAL REQUIREMENTS

If a Contractor generates or accumulates hazardous waste, i.e., mercury containing items, batteries, PCB ballasts, waste oils, off-spec fuels, waste paint related items, or aerosols, in addition to complying with ALL Federal, State, and Local Environmental Laws and Regulations, the Contractor must also follow the Fort Drum Hazardous Waste Management Plan (HWMP) procedures in notifying the Hazardous Waste Manager regarding the Use, Storage, and Ultimate disposal of any Hazardous Wastes (HW) to include Universal Wastes (UW) generated. The HW/UW must be disposed of within New York State Department of Environmental Conservation (NYSDEC) Laws and Regulations, for timeliness and proper Manifesting requirements. Fort Drum has an approved EPA ID number (NY0214020281) for the disposal of HW/UW from the Installation, this is the only EPA ID number that shall be used for disposal of Hazardous Waste generated at Fort Drum. Contractors will NOT use their own EPA ID number in any event to dispose of HW/UW that is generated on Fort Drum. The PW Environmental Division, HW Manager or appointed representative must review and sign the waste profiles/waste analysis, Land Ban restriction forms (if applicable), all manifests, and Bill of Ladings for waste that is generated on Fort Drum, prior to shipment off the Installation.

The Contractor must provide a copy of the New York State Regulating Authority permit for each treatment, storage, disposal or recycling facility utilized. Provide a letter to Fort Drum stating that they are authorized to receive the waste stream from Fort Drum.

The transporter of hazardous waste shall be licensed and/or permitted to transport hazardous waste IAW New York State Department of Environmental Conservation (NYSDEC) and Department of Transportation (DOT) regulations. The Contractor must provide a letter to Fort Drum stating that they are authorized to transport the waste

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Permit and driver’s license (Part 364) with hazmat endorsement. Questions and coordination regarding the disposal of HW/UW should be forwarded to the Fort Drum Environmental Division Hazardous Waste Program Manager at 772-4156.

3.7 HAZARDOUS MATERIALS CONTROL CENTER

The Supply and Services, Hazardous Material Control Center (HMCC), a hazardous materials management operation, is a comprehensive control system for managing Fort Drum’s hazardous materials. The HMCC is located in building P-1660 on Ontario Avenue. The HMCC serves as the only authorized point where hazardous materials can be procured, issued for use and returned for re- issue at the same location.

Material consumption, expiration dates, and replenishment of depleted stocks are all managed through a computerized system. Materials containing chlorinated solvents are not authorized on Fort Drum.

3.8 HAZARDOUS WASTE ANALYSIS

Hazardous waste generated from a process on Fort Drum must be analyzed to identify or verify the characteristics of the hazardous waste in order to satisfy the regulatory requirements for storage, transport and disposal. The text included in this section is presented as a guide for performing sampling and analysis of waste streams. All sample analysis shall be performed by a contracted laboratory certified by the New York State Department of Health Environmental Laboratory Approval Program for the analysis being conducted.

3.8.1 SAMPLING FREQUENCY

Analysis of samples from each known or suspected hazardous waste stream at Fort Drum is performed under the following conditions:

• When the waste stream changes or the process or operation generating the waste stream changes, making previous analytical results outdated;

• When proper waste segregation procedures are not followed, resulting in a potentially mixed waste stream;

• When regulatory changes regarding waste analysis or disposal procedures change significantly to require re-analysis; and,

• At a minimum, hazardous waste streams will be reviewed on a yearly basis. This yearly analysis may be based on generator knowledge and may not require sampling and laboratory analysis.

Fort Drum Public Works Environmental Division shall retain the records of any test

3-7 results or waste analyses for at least three years from the date that the waste was last sent to an off-site treatment, storage, or disposal facility pursuant to 40 CFR Part 262.4(c).

3.8.2 HAZARDOUS CHARACTERISTICS ANALYSIS

Fort Drum shall test its wastes for the following parameters in order to determine if the waste is considered RCRA hazardous, unless knowledge of process or materials indicates that one or more of the tests is unnecessary:

• Ignitability characteristic (40 CFR 261.21);

• Corrosivity characteristic (40 CFR 261.22);

• Reactivity characteristic (40 CFR 261.23);

• Toxicity characteristic for compounds regulated under RCRA (40 CFR 261.24); and, One or more of a number of specific elements and compounds listed in 40 CFR Part 261, in order to determine the identity of a potentially listed hazardous waste.

Specific details of analytical methods for single elements, ions, and compounds can be found in EPA "Test Methods for Evaluating Solid Waste," SW-846.

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SECTION 4

HAZARDOUS WASTE MANAGEMENT REQUIREMENTS

4.1 STANDARD OPERATING PROCEDURES

The following is a summary of required procedures associated with the management of hazardous waste at accumulation areas. Hazardous waste Satellite Accumulation Areas and the Less-Than-90-Day Hazardous Waste Central Accumulation Facility operations must comply with the following procedures. Any deviation from these procedures must be approved by the Public Works Environmental Division, Hazardous Waste Program Manager.

• The hazardous waste Satellite Accumulation Area must be at or near the point of generation and under the immediate control of the operator of the process generating the waste. A copy of the most recent Fort Drum Hazardous Waste Management Plan and the Oil and Hazardous Substance Spill Contingency Plan must be maintained at each facility generating and/or accumulating the waste.

Personnel responsible for generating, accumulating, and/or handling hazardous waste must READ and COMPLY with these documents. All personnel involved with managing or handling hazardous waste must be properly trained/briefed.

Public Works Environmental Division will provide training/briefing when required.

• A readily accessible spill control kit must be located within a reasonable distance of each hazardous waste accumulation area/facility. A current inventory of the spill kit must be available during inspections.

• “No Smoking” signs must be posted and clearly visible at all areas where flammable or ignitable hazardous wastes are accumulated.

• No open flame or any work that generates frictional heat or sparks will be allowed in the vicinity of a hazardous waste accumulation area/facility where flammable or ignitable wastes are present. A Hot Work Permit must be obtained from the Fire Prevention and Protection Division prior to commencement of any heat or spark-producing work.

• Each Satellite Accumulation Area and the Less-Than-90-Day Central

Accumulation Facility must be identified with a sign, which contains the following information:

- Accumulation area Point of Contact (POC) and alternate POC names and phone numbers.

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- The words “Caution - Hazardous Waste Accumulation Area - Authorized Personnel Only.”

- The words “In Case of Spill or Emergency, Call the Fort Drum Fire Department at 911.

• The Less-Than-90-Day Central Accumulation Facility and Satellite Accumulation

Areas must have a secondary containment system. Secondary containment must be provided for at least 10% of the total volume of the contained waste or 100% of the largest container, whichever is greater.

• The Less-Than-90-Day Central Accumulation Facility and Satellite Accumulation

Areas must be enclosed sufficiently to prevent the accumulation of precipitation on the lids of the waste containers and in the secondary containment system.

• All hazardous wastes must be collected and containerized immediately after they are generated in the designated accumulation container.

• Containers must be filled to no more than 80% of their capacity. For example, 55-gallon drums should be filled to approximately 6 inches from the top of the drum. By allowing sufficient head space, the risks presented by spills and overfilling are reduced.

• Wastes must be segregated by waste category and specific waste type.

Different types of waste must never be mixed during accumulation. Specific examples of wastes that must be accumulated separately include:

- Halogenated solvents (e.g., methylene chloride);

- Non-halogenated solvents (e.g., toluene, acetone, xylene);

- Used motor oil;

- Off-Spec fuel;

- Used antifreeze;

- Used refrigeration oil;

- Used battery acid; and

- Oily rags

Note: The above list is only a small example of waste streams that must be collected separately. Collecting any waste in containers must be approved by the Public Works Environmental Division, Hazardous Waste Program Manager at 772-4156.

• If two different types of waste are accidentally or knowingly mixed together in a container, accumulation of waste in that container must stop immediately and

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Public Works Environmental Division must be contacted for the proper procedure to follow. It takes only a very small quantity of hazardous material mixed with a non-hazardous waste to make the entire mixture characteristically hazardous.

For example, three to four drops of Tetrachloroethylene (hazardous) mixed with 55 gallons of ethylene glycol (non-hazardous) are sufficient to make the entire 55-gallon drum of ethylene glycol a characteristically hazardous waste.

• In the event of a fire, explosion or other release, which could threaten human health outside the facility or when the generator has knowledge that a spill has reached surface water the Environmental Division must notify the National Response Center immediately.

The report must include the following:

- The name, address, and U.S. EPA Identification Number of the generator;

- Date, time, and type of incident (e.g., spill or fire);

- Quantity and type of hazardous waste involved in the incident;

- Extent of injuries, if any; and

- Estimated quantity and disposition of recovered materials, if any.

• To prevent cross contamination of wastes, intermediate containers used to collect and/or transport wastes to the designated accumulation area must not be used for more than one specific waste type.

• If wastes are transferred from one accumulation container to a new container, the original container can be used to accumulate the same type of waste it originally held but cannot be used to contain a different type of waste. If the container is no longer needed, contact Public Works Environmental Division for proper disposal information.

• In addition to the requirements for segregating wastes into separate containers to allow proper disposal, containers with wastes that may be incompatible with each other must also be kept separate. By use of measures such as physical distance, berms, dikes, and/or containment pallets, potential leaks from incompatible wastes must be isolated from each other. Reactions that must be prevented are reactions that:

- Generate extreme heat, pressure, fire, explosions or violent reactions;

- Produce fumes, dust or gases in sufficient quantities to threaten human health or the environment;

- Produce uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosion

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- Damage the structural integrity of the containment devices or the facility; or

- Through other similar means threaten human health or the environment.

• Corrosives, such as battery acid, must be stored separately from ignitables, such as solvents and paints. Also, caustics must be stored separately from acids.

Reactives must be stored separately from corrosives and ignitables in a cool dry place. Examples of reactives are lithium batteries and calcium hypochlorite.

4.2 HAZARDOUS WASTE CONTAINER REQUIREMENTS

The purpose of these requirements is to ensure that the correct containers are used for the accumulation of hazardous wastes at Satellite Accumulation Areas and the Less-Than-90-Day Central Accumulation Facility, and to ensure that the areas around the containers are properly maintained.

• All containers used to accumulate hazardous waste must be approved by Public Works Environmental Division, Hazardous Waste Program. Containers may be obtained by calling the Hazardous Waste Program at 772-4156.

• Containers used for accumulation of hazardous waste must meet the following requirements:

- Containers must meet U.S. Department of Transportation requirements for transportation of the specific waste;

- Containers must be in good condition (have no major dents or corrosion) and have tightly fitting closure rings or bungs;

- Containers must be constructed of or lined with a material that will not react and is otherwise compatible with the hazardous waste it will be used for; and

- Containers must be properly labeled and marked.

• A container accumulating hazardous waste must remain closed at all times except when waste is placed into or removed from the drum.

• Storage or placement of any material on the top surface of any hazardous waste accumulation container is strictly prohibited. Funnels, rags, tools, material parts, boxes, or containers containing waste must not be placed or stored on the top surface of a drum.

• Hazardous waste accumulation containers and the surrounding area must be

4-4 kept clean at all times. Liquids dripped or spilled on the floor must be cleaned immediately to minimize hazards from chemical exposure and slipping.

• All hazardous waste accumulation containers must be readily accessible for removal and inspection. A minimum of 24-inches of aisle space between all hazardous waste accumulation drums and containers must be maintained at all times.

• Do not block drums with boxes, carts or other drums. Access between pallets or around the rows of containers must be maintained to allow easy visual monitoring for leaks and corrosion. ALL containers will have the label facing outwards so emergency responders can readily identify the contents of the drum in the event of an emergency.

• Containers must be opened, closed, and handled in a manner to prevent rupture or leakage of the containers.

• Liquid wastes must be accumulated in official DOT approved bung-top drums.

Solid wastes must be accumulated in open head drums with removable lids.

• If, at any time, corrosion or deterioration is detected in a container, measures must be taken immediately to insure that no release of hazardous waste occurs.

If a leak is already present or the container appears ready to start leaking, the waste should be immediately transferred to a new container or over-pack drum.

Contact the “You Call – We Haul” service, 772-6111, for assistance.

• Hazardous wastes generated due to disposal of off-specification, outdated, or excess materials must be kept in their original container with their original labels.

They may be placed into a secondary container compatible with the waste, if necessary, to protect against leakage.

4.3 HAZARDOUS WASTE CONTAINER LABELING

The purpose of these requirements is to ensure that all drums and containers used to accumulate hazardous waste at Satellite Accumulation Areas and the Less-Than-90- Day Central Accumulation Facility are properly marked and labeled.

All containers used for hazardous waste will be provided by Public Works Environmental Division, Hazardous Waste Program with all appropriate labels. Contact the PW Environmental, Hazardous Waste Program Manager at 772-4156, to obtain hazardous waste containers (empties) and contact the “You Call – We Haul” service at 772-6111, to coordinate pick-up and transfer of full hazardous waste containers.

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Accumulation point requirements for Dental amalgam waste is covered in Section 6, page 6-2.

4.3.1 SATELLITE ACCUMULATION CONTAINERS

• All drums and containers used to accumulate hazardous waste at a Satellite Accumulation Area must be clearly labeled with the following information:

- The words “Hazardous Waste”;

- A description of the waste being accumulated; and

- Marked with the hazard it presents.

Public Works Environmental, Hazardous Waste Program will provide pre-printed labels for all containers. The accumulation start date should not be written on the accumulation container when it is located at a Satellite Accumulation Area until it becomes full. It is the responsibility of the generator to write the start date on the container.

4.3.2 LESS-THAN-90-DAY ACCUMULATION CONTAINERS

• All drums and containers used to accumulate hazardous waste at the Less-Than- 90-Day Central Accumulation Facility must be clearly labeled with the following information:

- The words “Hazardous Waste”;

- A description of the waste being accumulated;

- The accumulation start date; and

- Marked with the hazard it presents.

Public Work Environmental Hazardous Waste Program will provide pre-printed labels. For wastes accumulating in the Less-Than-90-Day Central Accumulation facility, the accumulation start date is the date the hazardous waste is first added to the container. Information entered on the hazardous waste accumulation drum or container must be consistent with the hazardous waste records.

• Warning labels must be affixed to any container with asbestos material inside.

The warning label will be of sufficient size and contrast to be readily visible and legible. The label will state:

“CAUTION – CONTAINS ASBESTOS FIBERS

AVOID CREATING DUST

BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM”

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• Drums containing non contaminated used antifreeze, used oil, and off-spec fuels will not be labeled as hazardous waste. Containers of these materials need only be labeled with the description of the contents, e.g., “used oil.”

4.4 HAZARDOUS WASTE ACCUMULATION TIME AND VOLUME LIMITS

The purpose of this requirement is to ensure that RCRA hazardous wastes accumulated at Satellite Accumulation Area and the Less-Than-90-Day Central Accumulation Facility do not exceed time and volume limits, as mandated by RCRA. These procedures do not apply to used oil, used antifreeze, or other non-RCRA hazardous wastes, unless they are inadvertently mixed with hazardous waste such as solvents.

Dental amalgam waste is addressed as a Special Waste on pages 6-2 and 6-3.

4.4.1 SATELLITE ACCUMULATION AREAS

Time Limit: Unless the volume limit, as discussed below, is exceeded, there are no regulatory limits on how long hazardous wastes being accumulated may be present at a Satellite Accumulation Area. However, good management practices dictate that the volume of waste present at an accumulation point should be kept at a practical minimum. If a waste accumulation container has not been emptied or transferred for more than 6 months, the waste-producing process should be reviewed to determine if a smaller waste accumulation container is more appropriate.

Volume Limit: A maximum of 55 gallons of hazardous waste or one quart of acutely hazardous waste may be accumulated at a Satellite Accumulation Area. If more than one type of hazardous waste is accumulated at a Satellite Accumulation Area, the total volume of all hazardous wastes accumulated cannot exceed 55 gallons. If the volume limit is exceeded for hazardous or acutely hazardous waste, the excess must be moved to the Less-Than-90-Day Central Accumulation Facility. To ensure compliance with these requirements, the following procedures will be followed:

• No more than one container may be used at a time for accumulation of each type of hazardous or acutely hazardous waste. The total volume of all containers used to accumulate waste at a satellite accumulation point cannot exceed 55 gallons. The total volume for all containers used to accumulate acutely hazardous waste at a Satellite Accumulation Area cannot exceed one quart.

• When a container is full (80%), it must be dated with the date it became full and moved to the Less-Than-90-Day Central Accumulation Facility with–in three days.

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Contact the “You Call – We Haul” service at 772-6111, to request removal of full container and to provide a new container.

The accumulation start date (dated when the container is full), accumulation stop date (90 days after the accumulation start date), and the date the container was moved from the satellite accumulation area should be recorded to provide an audit record for the generator. This information is useful to show compliance, and it demonstrates best management practices.

4.4.2 LESS-THAN-90-DAY CENTRAL ACCUMULATION FACILITY

Time Limit: The following procedures containers in the Less-Than-90-Day Central Accumulation Facility will be followed:

• When a container of waste from a Satellite Accumulation Area is transferred to the Less-Than-90-Day Central Accumulation Facility, the container will be managed as a less-than-90-day-waste IAW the date it became full.

• When containers within the Less-Than-90 Day Central Accumulation Facility are within 65 days of the accumulation stop date, the Environmental Division Hazardous Waste Program will begin the process of coordinating disposal.

Volume Limit: There is no volume limit associated with accumulation of hazardous waste at the Less-Than-90-Day Central Accumulation Facility.

4.5 HAZARDOUS WASTE ACCUMULATION AREA INSPECTION

Satellite Accumulation Areas must be inspected every seven days by the generating facility manager or designated representative using the PW Environmental Hazardous Waste program inspection form. The inspection form will be provided by the PW Environmental Hazardous Waste Program Manager and can be reached at 772-4156.

The Less-Than-90-Day Central Accumulation Facility must be inspected every seven days by the generating facility manager or designated representative using the PW Environmental Hazardous Waste program inspection form.

The forms must be filled out completely, signed, and dated. Completed inspection forms will be provided to and retained by the PW Environmental Division Hazardous Waste Program Manager for a minimum of three years.

Any items found to be deficient or present a risk to personnel or the environment, such as a bulging or leaking drum, must be corrected immediately. Non-critical items found

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In addition to the weekly inspections to be performed by the hazardous waste generator, Satellite Accumulation Areas will be periodically visited by PW Environmental Hazardous Waste Program personnel to ensure compliance.

4.6 OFF-SPECIFICATION, OUTDATED, AND EXCESS HAZARDOUS MATERIAL

TURN-IN/DISPOSAL

A hazardous material that is off-specification, outdated, or excess does not necessarily require disposal as a waste. Military standards are frequently stricter than general industrial standards, which allow the government to sell some off-specification, outdated, or excess materials to non-military customers. A determination must be made as to whether the material will require disposal as a waste or whether the government can find an alternative market for the material.

If the off-specification, outdated, and/or excess hazardous material must be disposed of call the “You Call - We Haul” service at 772-6111, to arrange disposal. Unit/Activity must provide a Safety Data Sheet for each item at time of pick-up.

4.7 ITEMS REQUIRING DEMILITARIZING

It is the responsibility of the generating activity turning in items that require demilitarizing to ensure that it meets the requirements in accordance with DoD Manual 4160.22, Volume 3, “Demilitarization Procedural Guidance”. Units/Activities are required to complete a Certification of Demilitarization form for all items demilitarized. These forms must be signed by a technically qualified government representative, as designated by the responsible commander or agency chief, who actually witnessed the demilitarization. Call the “You Call – We Haul” service, 772-6111, to coordinate pickup of items. Completed demilitarization certificates, along with Safety Data Sheets, must be provided to the “You Call – We Haul” personnel at the time of pickup.

4.8 AMMUNITION AND EXPLOSIVES (AE) AND RESIDUE

The generating activity shall ensure that this property is properly inspected to determine the presence or absence of explosive hazards prior to turn in for disposal. The personnel certifying and verifying the inspection shall complete an Inert Certification in accordance with DoD 4160.21-M, “Defense Materiel Disposition Manual,” current edition, and DoD Instruction 4140.62, “Materiel Potentially Presenting an Explosive Hazard,” current edition. Call the “You Call – We Haul” service, 772-6111, to coordinate pickup of items. Completed inert certificates, along with Safety Data Sheets, must be provided to the “You Call – We Haul” personnel at the time of pickup.

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SECTION 5

UNIVERSAL WASTE MANAGEMENT

The U.S. Environmental Protection Agency has developed rules governing the management of certain hazardous wastes. Although still considered "hazardous" the Universal Waste Rules provide for reduced management and recordkeeping requirements.

5.1 DEFINITION

The following waste materials are considered Universal Waste:

• Fluorescent light tubes and LEDs (mercury, lead)

• High Intensity Discharge (HID) lamps (mercury, cadmium, antimony)

• High pressure sodium vapor lamps (mercury, cadmium, chromium)

• Mercury vapor lamps (mercury, cadmium, antimony)

• Mercury thermostats

• Nickel cadmium, nickel-metal hydride, lithium, magnesium and mercury…