Attachment_6_-_HW_PROCESSING_SOP_(CONTRACTING).docx

MEMORANDUM FOR RECORD

SUBJECT: Standard Operating Procedure (SOP) for the Handling, Transporting and Containerizing of Hazardous Waste (HW), Universal Waste (UW) and Non-Regulated (N/R) Waste at the Less Than 90 Day Hazardous Waste Facility.

1. PURPOSE: To establish appropriate procedures for required handling, transporting and containerizing of HW, UW and N/R Waste at the less than 90 Day HW facility, which is compliant with all State and Federal Regulations, and the Fort Drum Hazardous Waste Management Plan (HWMP).

2. SCOPE: This SOP is applicable to all Personnel, which in the course of their duty; handle HW, N/R and UW generated at locations on Fort Drum.

3. BACKGROUND: Fort Drum is a Large Quantity Generator of HW as defined in State regulations found at Title 6 New York Codes Rules and Regulations (NYCRR) Subparts 372.2, Standards Applicable to Generators of Hazardous Waste and 374-3 Standards for Universal Waste. As a Large Quantity Generator, Fort Drum has numerous locations where HW and UW is generated.

4. RESPONSIBILITIES: To avoid significant fines and Notices of Violation, a Large Quantity Generator of HW must manage that waste IAW Federal, State, and Local regulations.

a. General

1. HW/UW may be generated in many ways; expired HM, process generated, contaminated HM, spill clean-up debris, etc. and could be generated at various locations, including households. Regardless of how or where HW/UW is generated, it must be processed IAW Environmental Laws and Regulations by proper segregation, labeling, storing and ultimate disposal and must conform to rigorous standards.

2. Generally, notification that an Activity has HW/UW or NR waste for disposal is via a phone call to the “You Call – We Haul” service phone line, 772-6111, requesting a pick up. This waste may also be identified during a routine Courtesy Assistance Visit or Satellite Accumulation Point (SAP) inspection. Unidentified HW could also be Found on Post (FOP). Waste may also be dropped off by residents of Mountain community Homes and Single Soldier Housing.

b. Transporters of Hazardous Waste Responsibilities:

1. Pick up all Hazardous Waste, all Universal Waste, items requiring Demilitarizing, any containerized non-hazardous waste liquids in excess of one gallon from all Fort Drum customers/Units on a recurring basis. Transport this waste to the designated Government HW Facility.

2. When waste is picked up, completely fill out a customer turn in receipt on one of the provided “Receiving Record” pads by documenting; the Unit/Activity name, building number, a Point of Contact Name, phone number, and an itemized list of all the waste being picked up, i.e. type of waste by name, quantity, container size etc. for each separate waste item. If an item does not contain a label the Motor Vehicle Operator will get identification from the Customer and write what the waste is on the container. Obtain an MSDS for any new or non-recurring item from the Customer prior to turn-in. All non-hazardous solid waste (exception are those requiring demilitarization) will not be picked up. In the event a Customer has non-hazardous solid waste and/or empty containers to turn in, present the customer with the most current version of the Fort Drum Waste Disposal Procedures handout, provided by the Environmental Division, describing the proper disposal procedures for non-hazardous waste and recyclables.

3. Have the Customer sign and print their name after the list of items on the Receiving Record. Receiver will initial at the bottom of the Receiving Record and give the yellow copy to the Unit/Activity POC for their records prior to transporting the waste. Keep remaining copies accessible on the clipboard during transport.

4. Overpack any HW containers found to be deteriorated or leaking prior to transporting. All HW containers taken to the designated Government HW Facility must be transported in a safe manner, properly segregated, not leaking, and protected by the weather.

5. Transport the waste in a Government vehicle to the designated Government HW Facility Warehouse for initial processing. Remove the white copy of the Receiving Record and provide to the designated Government Personnel.

6. Fluorescent light tubes: Full boxes of fluorescent light tubes will be picked up from the PW Electric shop’s designated collection point. Transport boxes to the designated HW Facility. Upon arrival weigh boxes, write weight on the boxes and place on a pallet in the designated fluorescent storage area. If there are no Government Personnel available, fill out a white Universal Label indicating Fluorescent Tubes and a start date and place on each box.

Fluorescent light tubes from areas other than the PW Electric shop are to be put into an accumulation box, located in the fluorescent tube storage area. If there is no accumulation box in use, procure a box from the warehouse area and bring the box to the fluorescent tube storage area. Place the fluorescent tubes in this new box and secure the box. If there are no Government Personnel available, fill out a white Universal Label indicating Fluorescent Tubes and a start date and place on the box.

Pallets of fluorescent tubes are to be no more than four (6) boxes high. All boxes of fluorescent light tubes must remain closed, except when adding waste, and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions.

7. Indoor Range Filters: Ensure that Range Division has taped all indoor range filter boxes prior to transporting to prevent lead dust from leaking out. Under no circumstance will boxes that are not adequately taped be transported. Write number of boxes on the Receiving Record, complete remaining information IAW number Two (2) above, and transport to the designated Government HW Facility. When arriving at the facility place the boxes on a pallet. Shrink wrap the pallet. If no Government Personnel are available fill out two red and white hazardous waste labels with the following information: “Range filters”, and the appropriate start date. Place one of these labels on opposite sides of the palletized boxes. Weigh pallet and write weight on the wrapped pallet. At times it may be necessary to create more than one pallet. Move pallets to the designated toxic storage area.

8. Non-Rechargeable Batteries: When processing non-rechargeable batteries, place in the appropriate accumulation container according to battery type, located in the designated Government HW Facility’s battery storage area. Ensure that the container is adequately closed to prevent spillage. If there is no accumulation container, obtain one from the warehouse area and bring to the battery storage area. If there are no Government Personnel available place a purple Universal Waste label (available in the battery storage room) on the drum and write the type of battery and the start date on the label. When containers are full, weigh them and write the weight using a marker on the top of the container.

To avoid significant fines and Notices of Violation, lithium batteries must managed as a universal hazardous waste. When a turn-in is requested:

a. HW Handlers will bring an appropriately sized container to transport the batteries.

b. HW Handlers will maintain at least five gallons, at a minimum, of vermiculite and baggies on the vehicle at all times to package any damaged batteries.

c. Upon arriving at the turn-in site HW Handlers will evaluate the batteries to ensure:

(1) That no battery is releasing gas.

(2) That no battery is warm to the touch.

(3) That no battery is wet.

(4) That all batteries are intact, not damaged or bulging.

(5) That all batteries with protruding terminals are taped.

d. DANGER - If there is evidence of any hissing sound or strong pungent gas (rotten egg odor), HW Handlers will immediately clear the area and call the Fire Department.

e. If batteries have been discharged (CDD switch activated) and they are still warm to the touch, immediately notify the unit/activity that the batteries are to remain at the unit/activity for the next seven days. At the end of the seven day cool down period HW Handlers will return to overpack and transport to the HW facility.

f. If any lithium batteries are damaged, cracked, or bulging, but not venting, immediately don a respirator and place battery in a plastic baggie and then into a shipping container adding enough vermiculite to sufficiently cover the battery. HW Handlers will then transport the container to the designated Government HW Facility. Damaged batteries are to be placed one to a container.

g. If any batteries having protruding terminals are not taped, employees will notify the unit/activity requesting that they be taped, using clear tape. In the event that there are several batteries that need taping, it may be necessary to reschedule the pickup. HW Handlers will provide the unit/activity with a copy of the attached Fort Drum HW Program memo.

h. When all batteries have been evaluated and cleared of any of the above conditions, employees will carefully place batteries into PW ENV HW provided container and transport to the designated Government HW Facility. Upon arrival to the facility, batteries must be placed into a container according to type. No mixing of different lithium batteries.

9. Rechargeable Batteries: When processing rechargeable batteries, place each battery into a plastic bag, located on the shelving unit in the designated battery storage area, and place in the appropriate Call2Recycle accumulation box according to battery type, also located on the shelving unit. When the box becomes full, close and tape the box, weigh and write the weight on the box. For internal tracking purposes, also record the date, type and weight on the clipboard located on the storage shelf. Notify designated Government Personnel that the box is full. If there are no boxes in place, prepare one (located on shelving unit). Write the accumulation state date on the box at the designated area. Inform the Government Personnel that there is a new box.

10. Latex Paint: When processing latex paint, inspect all one gallon cans. Those found to be totally solidified will be disposed of in the dumpster. All others will be drained into the latex paint accumulation container, located in the designated non-regulated storage area. Wipe up any spills or splatter. Ensure that the container is adequately closed to prevent spillage. If there is no accumulation container, obtain one from the warehouse area and bring to the designated non-regulated storage area. If there are no Government Personnel available, place a non- regulated label on it (available in non- regulated, non-hazardous storage area). Write “Latex Paint” on label. Ensure lid is adequately closed to prevent spillage. Replace lids on empty paint cans and place in the designated recycle container. When this recycle container becomes full, remove bag and replace with a new one. Take full bag to the designated Fort Drum recycling area. The cans with more than one inch of remaining hardened paint will also have lids replaced and be placed into the dumpster. When accumulation container is full weigh it and using a marker, write the weight on container. Notify the Government Personnel that the container is full.

11. Enamel Paint: When processing enamel paint, inspect all one gallon cans of enamel paint. Those found to be totally solidified (100% dry) will be placed in the dumpster. Those that have liquid will be drained into an accumulation container, located in the designated flammable storage area, wiping up any spills or splatter. Using a metal spoon scoop out all wet paint sludge. Replace lids on empty cans and place cans in the designated recycle container. When this recycle container becomes full, remove bag and replace with a new one. Take full bag to the designated Fort Drum recycling area. When finished decanting ensure accumulation container is adequately closed to prevent spillage. When accumulation container is full, weigh it and using a marker, write the weight on container. Notify the Government Personnel that the container is full.

NOTE: ENSURE THAT PAINT PRODUCT DOES NOT CONTAIN A REACTIVE CATAYLST. THESE MUST NOT BE MIXED AND MUST BE STORED IN THE DESIGNATED REACTIVE STORAGE AREA!

If there is no accumulation container, obtain one from the warehouse area and bring to the designated flammable storage. If there are no Government Personnel available, place a red and white label (available in the designated flammable room) on the container. Write “flammable paint” and the start date on the label and proceed IAW above paragraph.

12. Fuel: Empty all fuel into the off-spec fuel accumulation container located in the designated flammable storage area, wiping up any spills or splatter. Ensure container is adequately closed when finished to prevent spillage. If there is no accumulation container, obtain one from the warehouse area and bring to the designated flammable storage area. If there are no Government Personnel available place a non-regulated label (available in the designated non-reg storage area) on the container. Write “off-spec fuel” on the label. When the container is full using the vacuum pumping truck pump out the fuel.

13. Oil: If any oil is suspected of containing solvents notify the designated Government Personnel. Place all other oil into the oil accumulation container located in the designated non-regulated/hazardous storage area, wiping up any spills or splatter. Ensure container is adequately closed when finished to prevent spillage. If there is no accumulation container, obtain one from the warehouse area and bring to the designated non-reg storage area. If there is no Government Personnel available place a non-regulated label on it (located in the designated non-reg room). Write “Used Oil” on the label. When the container is full using the vacuum tuck, pump out the oil.

14. Antifreeze: Empty all antifreeze into the antifreeze accumulation container located in the designated non-regulated/hazardous storage area, wiping up any spills or splatter. Ensure container is adequately closed when finished to prevent spillage. If there is no accumulation container, obtain one from the warehouse area and bring to the designated non-regulated storage area. If there is no Government Personnel available, place a non-regulated label on the container, (available in the designated non-regulated/hazardous storage area). Write “used antifreeze” on the label. When container is full, pump the anti-freeze out.

15. Aerosol cans: See Standard Operating Procedure for Evaluating, Depressurizing and Reissuing of Aerosol Cans.

16. For all other waste, place into containers if necessary, ensure the container is adequately closed to prevent spillage, and then weigh. Write weight on container. If there is no Government Personnel available fill out a “red and white” hazardous waste label with the contents and start date and place on container. Place container in the designated storage area depending on the waste characteristic, i.e., flammable, toxic, or corrosive.

c. Additional HW storage requirements:

1. All containers must have labels facing forward.

2. All containers will have enough clearance space to allow for quick, easy removal in case of an emergency. Rooms with a rack will have smaller containers, i.e. 5 gallon or below, placed on these racks.

5. POINT OF CONTACT: For more information regarding this SOP, please contact the Hazardous Waste Program Manager, at 772-4156.

Michael S. Nuckols Chief, Compliance Branch Environmental Division

Revision control of this document is maintained electronically.

If printed, individuals are responsible for ensuring use of latest revision.