W911SA-21-Q-3008 Attachment 12 FMR 420-25.pdf

Fort McCoy Regulation 420-25

Public Works

Hazardous Waste/Material

Management Plan

Department of the Army Headquarters Fort McCoy

Fort McCoy, WI September 2009

UNCLASSIFIED

SUMMARY of CHANGE

Regulation 420-25 Hazardous Waste/Material Management Plan

This revision - -

DSS was replaced with DPW throughout the Plan.

Environmental Branch was replaced with Environmental Division throughout the Plan.

DES/DPTMS has been changed to separate directorates.

New Commander and Publications Manager names have been updated.

Figure 3-1 has been updated to most recent reporting year.

Section 6-3.c. has been updated to reflect 2007 regulatory manifest requirements.

Removed building 2199 from a Satellite Accumulation Point (SAP) status.

All phone numbers have been checked or revised if incorrect.

The entire Plan has been reviewed and revised where necessary for accurate language use, spelling and format.

Revision April 2007 - -

The majority of the plan has been updated to reflect changed installation conditions, include greater clarity and explanations of applicable regulations, and better documentation of on-going activities/practices.

Updated the section on listed hazardous waste to reflect current listings.

The definition of universal waste has been updated to include the recent change for mercury-containing equipment.

A definition of Hazardous Material has been added to the plan.

A discussion of pesticide wastes has been added to the plan.

The list of parties with hazardous waste responsibilities has been revised and expanded to include the

Army Contracting Agency (ACA), Fort McCoy contractors, and other hazardous waste disposal contractors. Also, changes in responsibilities for the DPW Environmental Division and specific changes for hazardous waste generators have been included (see section 2).

The list of Fort McCoy’s current hazardous waste minimization programs has been expanded (section 3-3). Figure 3-1 was also updated.

Reorganized section 4-4 for clarification of Hazardous Waste Accumulation Points and Satellite Accumulation Points.

Hazardous waste turn-in procedures have been updated to reflect actual operations (section 5).

Table 5-1 was added to provide specific instructions for the handling/disposal of common wastes.

A section has been added to describe the process for management of oil-water separators (section 5-

5). A standard operating procedure (SOP) has also been included with this plan to describe the necessary maintenance, monitoring, and cleanout of these units (appendix F). This SOP requires periodic monitoring of some of these units to measure product/sediment levels.

A section has been added to document waste profile and sampling requirements for the characterization of unknown/mixed waste streams (section 5-6). Information on laboratory analysis requirements has also been added.

A section has been added to document the installation’s procedures for developing a waste profile via laboratory analysis.

A section has been added to describe the database system now used for tracking hazardous waste containers, manifests, and profiles as processed by the DPW Environmental Division (section 6-2).

Documentation and further descriptions of the various elements of this database are provided in appendix D.

A section has been added to describe landfill disposal restriction requirements and associated paperwork as it pertains to waste shipments (section 6-4).

Some facilities have been dropped from the semi-annual visit list (appendix E) due to minimization of hazardous materials use/storage or their elimination of hazardous waste accumulation points. These include the water system pumphouses (buildings 5020, 5021, and 7061), 788th EOD shop (building

1459), MATES facility (buildings 242, 243, and 747) and the Rumpel Fitness Center (building 1122).

The Medical Clinic (building 2669) and Dental Clinic (building 2668) have been added to the semi-annual visit list (appendix E).

The TES shop (buildings 446 and 447) was added to the semi-annual inspection list.

Requirements for documentation and follow-up actions associated with site inspection deficiencies have been updated to reflect the re-checks and ICAP reporting that is now being performed by the DPW Environmental Division.

The hazardous waste/material site inspection checklist has been updated and included in this plan.

Training requirements have been updated to include non-hazardous waste site worker training requirements (section 8).

Table 8-1 was added to the plan to provide greater clarification for hazardous materials/waste training requirements.

Changed the requirement for DOT hazardous material training from three to two years per Defense

Transportation regulation DOD 4500.9-R, Part II, chapter 204.

A new training requirement has been added for satellite accumulation point managers. This training will be conducted in addition to the spill prevention training required by Fort McCoy Regulation 420-28, and will be offered by the DPW Environmental Division numerous times throughout the year (when appropriate). The course is intended to provide proper materials/waste management/disposal procedures.

The MATES facility has its own waste management program and plan, therefore appropriate references to this program/plan were included and the facility has been deleted from the list in appendix E.

Revision September 2004 - -

� The Hazardous Waste Management Plant was updated in its entirety to meet new regulatory requirements (all sections).

Fort McCoy Regulation 420-25 September 2009 ii

CONTENTS

Section 1 Introduction, page 1

Purpose 1-1, page 1 References 1-2, page 1 Operating Permits 1-3, page 1 Hazardous Waste Definition 1-4, page 1 Asbestos, Polychlorinated Biphenyls (PCBs), and Pesticides 1-5, page 3 Radioactive Waste 1-6, page 3 Infectious Waste 1-7, page 3 The Mixture Rule 1-8, page 3 Material Safety Data Sheets (MSDSs) 1-9, page 4 Universal Wastes 1-10, page 4 Hazardous Material 1-11, page 5

Section 2 Installation Responsibilities, page 5

Federal and State Regulators 2-1, page 5 Garrison Commander 2-2, page 5 Directorate of Public Works (DPW) 2-3, page 6 DPW Environmental Division 2-4, page 6 Directorate of Logistics Transportation Division 2-5, page 7 Defense Reutilization and Marketing Office (DRMO) 2-6, page 7 Other Hazardous Waste Contractors 2-7, page 7 Hazardous Waste Generators 2-8, page 8 Directorate of Plans, Training, Mobilization and Security (DPTMS) 2-9, page 8 Directorate of Emergency Services (DES) 2-10, page 8 Installation Safety Office (ISO) 2-11, page 8 Mission and Installation Contracting Command (MICC) 2-12, page 9 Installation Legal Office (ILO) 2-13, page 9 Public Affairs Office (PAO) 2-14, page 9 Resource Management Office (RMO), Program Budget Division 2-15, page 9 Contact Phone List 2-16, page 9

Section 3 Hazardous Waste Minimization, page 10

Waste Minimization Regulations 3-1, page 10 Fort McCoy Hazardous Waste Minimization Goals 3-2, page 10 Fort McCoy’s Current Waste Minimization Activities 3-3, page 11 Fort McCoy’s Future Waste Minimization Activities 3-4, page 12

Section 4 Hazardous Waste Storage, page 12

Hazardous Waste Containers 4-1, page 12 Empty Containers 4-2, page 13 Types of Hazardous Waste Generators 4-3, page 13 Hazardous Waste Accumulation Points and Satellite Accumulation Points 4-4, page 14 Managing SAPs 4-5, page 15 Locating SAPs 4-6, page 16 Special Hazardous Waste Storage Areas 4-7, page 16 Hazardous Materials Storage Areas 4-8, page 16

Fort McCoy Regulation 420-25 September 2009 iii

CONTENTS (continued)

Section 5 Hazardous Waste/Material Turn-in Procedures, page 16

Permanent and Tenant Activities at Fort McCoy 5-1, page 17 Troops Training at Fort McCoy 5-2, page 17 Common Fort McCoy Hazardous, Universal, and Special Wastes 5-3, page 18 Turn-in of Radioactive Material, Polychlorinated Biphenyls, and Waste Pesticides 5-4, page 19 Oil-Water Separators 5-5, page 20 Waste Profiles 5-6, page 20 Waste Analysis Plan 5-7, page 20 Waste Shipment Preparation 5-8, page 21

Section 6 Manifest and Hazardous Waste Tracking, page 21

Annual Hazardous Waste Disposal 6-1, page 21 Hazardous Waste Database 6-2, page 21 Uniform Hazardous Waste Manifests 6-3, page 21 Landfill Disposal Restrictions (LDRs) 6-4, page 22

Section 7 Generator Site Visits/Inspections, page 23

Site Visits/Inspections 7-1, page 23 Deficiencies 7-2, page 23

Section 8 Training Requirements, page 23

Required Training 8-1, page 25 New Employees 8-2, page 25 Trainers 8-3, page 25 Recordkeeping 8-4, page 25

Section 9 Operating Permits, page 25

Permit Process 9-1, page 25 EPA Identification (ID) Number 9-2, page 25

Section 10 Spill Prevention Control and Countermeasure and Installation Spill Contingency Plans, page 26

Appendices

A. References, page 27 B. Acronym List, page 28 C. Material Safety Data Sheet User Guide, page 30 D. Standard Operating Procedure, DPW Environmental Division Hazardous Waste Database, page 33 E. Waste Generator List and Semi-Annual Visit Schedule, page 36 F. Standard Operating Procedure, Oil-Water Separator Maintenance and Monitoring, page 37

Fort McCoy Regulation 420-25 September 2009 iv

CONTENTS (continued)

Tables

2-1. Contact Phone List, page 9 4-1. Headspace Allowance per Container, page 13 5-1. Common Fort McCoy Hazardous, Universal, and Special Waste, page 18 8-1. Training Requirements, page 24 F-1. Oil-Water Separator List and Maintenance Schedule, page 38

Figure

3-1. Annual Hazardous Waste Amounts, page 11

Fort McCoy Regulation 420-25 September 2009 1

Section 1 Introduction

1-1. Purpose The Hazardous Waste Management Plan assigns responsibilities and creates procedures for hazardous waste and materials handling. The plan also fulfills the requirements of the following:

a. Title 40 Code of Federal Regulations (40 CFR) Parts 260-280

b. Title 49 Code of Federal Regulations (49 CFR) Parts 100-185

c. Wisconsin Department of Natural Resources (WDNR) Wisconsin Administrative Code, chapters NR 660-679

d. Army Regulation 200-1

1-2. References References used in this plan can be found in appendix A.

1-3. Operating Permits Fort McCoy's Environmental Protection Agency (EPA) hazardous waste identification number is WI3210020563. Fort McCoy is not currently required to obtain any hazardous waste operating permits;

however, the installation must follow regulations imposed upon large quantity generators. Further information on hazardous waste permits is found in section 9.

1-4. Hazardous Waste Definition Solid waste is defined as any discarded gas, liquid, or solid material that is not excluded by 40 CFR 261.4(a). An item is discarded when it is abandoned, recycled, or considered inherently waste-like. The discarded items include materials that are contaminated, spent, have an expired shelf-life, in a leaking container, and/or are no longer usable for their intended purpose. Hazardous waste is a sub-set of solid waste.

a. Hazardous wastes are any gas, liquid, or solid waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment. Hazardous wastes have one or more of the four hazardous waste characteristics or are specifically listed as a hazardous waste. The four characteristics of hazardous wastes are: ignitibility, corrosivity, reactivity, and/or toxicity. The specifically listed wastes are wastes from non-specific sources, specific sources, or commercial chemical products.

b. Characteristic Wastes: A waste is characteristically hazardous if it exhibits any of the following characteristics.

(1) Ignitability. The flash point is the measure of ignitability for a particular material. A flash point is the point at which the material produces sufficient vapor concentrations that are ignitable when mixed with air. The U.S. Department of Transportation (DOT) regulations state that a liquid with a flash point of 141 degrees °F or below is considered “flammable”. A liquid that has a flash point between 141 °F and 200 °F is defined as “combustible”. Ignitable wastes have the EPA waste code of D001 (in accordance with 40 CFR 261.21(b)). According to Wisconsin regulations, ignitable wastes are defined as materials with the following properties:

(a) Liquids with a flash point less than 140 °F.

(b) A non-liquid that is capable under standard temperature and pressure (STP) of causing fire or sustained burning and is considered as causing a hazard.

(c) An ignitable compressed gas.

Fort McCoy Regulation 420-25 September 2009 2

(d) An oxidizer, under DOT regulations (49 CFR) and indicated on the container label.

(2) Corrosivity. Corrosive wastes are defined as liquids having a pH of less than or equal to 2, or greater than or equal to 12.5. Corrosive wastes have an EPA waste code of D002.

(3) Reactivity. Reactive wastes have an EPA waste code of D003. Reactivity is defined through the material exhibiting any of the following characteristics:

(a) It is unstable.

(b) It is water reactive.

(c) It forms an explosive mixture when mixed with water.

(d) It generates a toxic gas when mixed with water.

(e) It is a cyanide/sulfide waste that can generate toxic gases or vapors.

(f) It can create an explosive reaction if subjected to a strong initiating source or heated when confined.

(g) It can create an explosive reaction or is capable of detonation at STP.

(h) It is a forbidden, Class A, or Class B explosive.

(4) Toxicity. Toxic wastes contain materials that have leachate concentrations greater than the thresholds for any of the substances listed in 40 CFR 261.24, Table 1 and Wisconsin Administrative Code NR 661.24, Table 2. Leachate concentrations are determined by the Toxicity Characteristic Leaching Procedure (TCLP). Toxic wastes are assigned the EPA waste codes of D004 to D043.

c. Listed Wastes are hazardous regardless of their component concentration and must be handled according to the EPA’s Subtitle C hazardous waste regulations. Listed waste is grouped into four categories:

(1) F-Wastes are from non-specific, generic sources (EPA waste codes of F001-F039) including common manufacturing and industrial processes. Currently, the only F-Waste that Fort McCoy generates is spent solvents/thinner from the painting operations at the Installation Materiel Maintenance Activity (IMMA) facility. The installation has converted many of its parts washers and degreasers such that they no longer use materials that would produce F-Wastes (see section 3-3).

(2) K-Wastes are from source-specific manufacturing processes (EPA waste codes of K001-K178).

Sludge and wastewater generated from petroleum refining and wood preserving processes are examples of source-specific wastes. Currently, Fort McCoy does not generate any K-Wastes.

(3) U-Wastes are unused, toxic commercial grade products (EPA waste codes of U001-U409).

Fort McCoy occasionally generates small volumes of U-Waste from miscellaneous processes or unused materials. U-waste also applies to wastes that only contain the listed chemical or in which the listed chemical is the only active ingredient.

(4) P-Wastes are unused, acutely hazardous chemical products (EPA waste codes of P001-P205).

The P listed wastes are reserved for discarded commercial chemicals, off specification chemicals, container residues, and spill residues of P listed chemicals. P-waste also applies to wastes that only contain the listed chemical or in which the listed chemical is the only active ingredient. Similar to the U- Wastes, Fort McCoy occasionally generates small volumes of P-Wastes.

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1-5. Asbestos, Polychlorinated Biphenyls (PCB), and Pesticides Asbestos, PCB containing wastes, and pesticide wastes are often mistakenly identified as hazardous wastes. However, wastes containing these constituents are regulated under the Toxic Substances Control Act (TSCA) or the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) as compared to the RCRA regulations for hazardous waste as described above. TSCA regulates chemical manufacturing and chemical use. Through TSCA the EPA has the authority to identify and evaluate potential chemical substances and regulate their production, use, distribution, and disposal.

a. Asbestos is a naturally occurring fiber that was commonly used in insulation and fire-proofing material. Asbestos containing materials (ACM) may release fibers that when inhaled can cause the respiratory diseases asbestosis and mesothelioma. In Wisconsin, work conducted with ACM is regulated under Wisconsin Administrative Code, chapters NR 447 and HFS 159. The transport and disposal of ACM is regulated under NR 500 series regulations. For more information contact the DPW Environmental Division, (608) 388-2160.

b. PCB are heavy, oily liquids and waxy solids manufactured primarily by the Monsanto Corporation from 1929 until 1977. PCB were used in heat transfer systems, refrigeration compressor units, paints, hydraulic systems, caulks, sealants, and as a dye carrier in carbonless paper. PCB were also used in transformers, switches, voltage regulators, and fluorescent light ballasts. In Wisconsin, the management of PCB containing waste is regulated under NR 157 and landfill requirements for PCB wastes are provided in NR 500 series regulations. For more information contact the DPW Environmental Division,

(608) 388-2160.

c. Other chemical substances regulated under TSCA are:

(1) Chlorofluorocarbons (i.e., refrigerants; also regulated under the Clean Air Act).

(2) Hexavalent chromium used in industrial cooling towers (also RCRA hazardous wastes).

(3) Metal working fluids (these can also be RCRA hazardous wastes).

(4) Dioxins.

d. Pesticides are products that are used for preventing, destroying, repelling, or mitigating any pest, or intended for use as a plant regulator, defoliant, or desiccant. Some pesticides are regulated under RCRA, while others are regulated under FIFRA. More information on pesticide management is contained in the Fort McCoy Regulation 200-3, Integrated Pest Management Plan (IPMP).

1-6. Radioactive Waste Radioactive wastes are also not hazardous wastes according to RCRA regulations. The Nuclear Regulatory Commission (NRC) and the US Department of Energy (DOE) regulate these wastes under the Atomic Energy Act (AEA). RCRA excludes certain radioactive wastes from the solid waste definition.

However, if a radioactive waste is mixed with a hazardous waste, then both the RCRA and AEA regulations apply. Contact the Installation Safety Office, (608) 388-3403 for assistance with disposal of radioactive wastes.

1-7. Infectious Waste Infectious waste is a hazardous material but is not hazardous waste according to RCRA regulations.

Therefore, handling and shipping infectious waste is regulated under 49 CFR. For assistance with handling and disposal of infectious waste, contact the Troop Medical Clinic at (608) 388-3025.

1-8. The Mixture Rule The appropriate segregation of wastes can minimize hazardous waste generation volumes and disposal costs. In accordance with 40 CFR part 261.3, if a hazardous waste is mixed with a non-hazardous waste, the whole mixture becomes hazardous. For example, if one gallon of waste acetone (an F and U-Waste) is mixed with 54 gallons of water, the whole 55-gallon mixture is hazardous (with an EPA waste code of

Fort McCoy Regulation 420-25 September 2009 4

F003). The mixture rule does not apply in the same strict manner to characteristic wastes as it does to listed wastes. For example, a mixture of an ignitable waste and a non-hazardous waste may not be hazardous if the mixture is not ignitable. However, wastes cannot be intentionally diluted or mixed in order to remove a hazardous waste characteristic. These wastes must be properly disposed.

1-9. Material Safety Data Sheets (MSDS) MSDS provide health, environmental, emergency response, and other safety information on hazardous materials. The MSDS also includes chemical composition, physical characteristics, fire and explosion data, health hazards, and precautions for safe handling. MSDS are a requirement under Sections 311- 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA).

a. Supervisors must ensure an MSDS is present at the workplace for every hazardous material used in the workplace. MSDS are provided with materials purchased through Army procurement channels. When materials are procured locally, the purchaser should request an MSDS from the seller. Additionally, several websites, including manufacturer websites, are available to obtain MSDS. Other ways to find lost or out-of-date MSDS include:

(1) Calling the product manufacturer.

(2) Checking with the appropriate Supply personnel.

(3) Using the Hazardous Material Information System (HMIS). HMIS is now on the Fort McCoy computer domain. HMIS contains MSDS and are obtainable by entering the material’s National Stock Number. HMIS does not contain MSDS for locally purchased items. Please contact the Network Enterprise Center (NEC) at (608) 388-3737 for information on how to access this software.

(4) Calling the DPW Environmental Division, (608) 388-2160.

b. An MSDS is also needed for disposal of a used commercial chemical product. The MSDS often provide sufficient data for establishing a profile for the waste stream, see section 5-6. An MSDS users guide is provided in appendix C.

1-10. Universal Wastes

a. On May 11, 1995, the EPA finalized its Universal Waste Rule. The goal of the final rule is to separate universal waste from the municipal waste stream. The following are universal wastes subject to this rule:

(1) Waste batteries: Many batteries can be managed as universal waste, including nickel cadmium, magnesium, silver, and lithium batteries. This also includes lead-acid batteries, which are currently regulated under Subpart G of 40 CFR 266. Alkaline and non-alkaline (heavy duty; carbon-zinc) batteries are not currently regulated by the Universal Waste Rule. These batteries can be disposed of as solid waste.

(2) Waste thermostats: A waste thermostat is any temperature control device that contains metallic mercury in an ampule attached to a bimetal-sensing element. This definition also includes mercury containing ampules that have been removed from these thermostats. Removal must be done over a containment pan and in a manner that prevents breakage of the ampules.

(3) Waste pesticides: Certain waste pesticides are considered universal wastes. These include unused pesticides that have been suspended or canceled under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), recalled pesticides, and those that are collected for disposal. Proper use and disposal requirements for these pesticides are included in the installation’s Integrated Pest Management Plan (IPMP), Fort McCoy Regulation 200-3. A copy of this plan can be found on the Fort McCoy Corporate website or can be obtained from the DPW Environmental Division (388-2160).

Fort McCoy Regulation 420-25 September 2009 5

(4) Waste lamps/light bulbs: Some light bulbs and lamps use hazardous materials. Examples of common universal waste electric lamps include fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps.

(5) Other mercury-containing equipment: On August 5, 2005 the EPA published a final rule that revised regulations on miscellaneous mercury containing equipment, such as certain switches and atmospheric gauges. When discarded, this equipment may now be classified as a universal waste. This exemption does not apply to used dental amalgam.

b. Each universal waste or container holding the waste must be labeled. Suggested labels for each waste are provided in Table 5-1. Universal waste pesticides must have these markings plus additional labeling requirements i.e., as much specific information on the type of material as possible.

c. Universal wastes may be accumulated for one year from the date the waste was first generated.

Therefore, these wastes must be containerized upon receipt and each container must include the start date. Universal wastes can be brought to building 207 for disposal prior to the one year accumulation date of the waste.

d. The WDNR requires all universal waste shipments to be tracked using shipping documents ,i.e., manifests. However, universal wastes cannot be shipped using Hazardous Waste Manifests. All universal wastes transported off Fort McCoy will use a Bill of Lading or Non-Hazardous Waste Manifest. One copy of the Bill of Lading or Non-Hazardous Waste Manifest goes to the Defense Reutilization Marketing Office (DRMO) (the organization that currently contracts for handling Fort McCoy’s hazardous waste) and another copy goes to the DPW Environmental Division. Each document must include: a description of the type of waste being shipped, the name and address of the receiving facility, the quantity in pounds, the date of shipment, and release/turnover signatures for the generator, shipper, and receiving facility.

e. Records must be kept for at least three years pursuant to 40 CFR 279.39(c).

1-11. Hazardous Material Per 49 CFR 171.8, a hazardous material means a substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and has designated as hazardous under section 5103 of Federal hazardous materials transportation law (49 U.S.C. 5103). The term includes hazardous substances, hazardous wastes, marine pollutants, elevated temperature materials designated as hazardous in the Hazardous Materials Table and materials that meet the criteria for hazard classes and divisions located within 49 CFR, chapter 1, part 173 subchapter C, see 49 CFR 172.101.

Section 2 Installation Responsibilities

2-1. Federal and State Regulators The EPA and the WDNR are the regulatory agencies responsible for the enforcement of hazardous waste regulations. Enforcement is accomplished by unannounced inspections. These inspections evaluate Fort McCoy’s adherence to the applicable hazardous waste regulations for large quantity generators.

2-2. Garrison Commander The Garrison Commander is legally responsible for proper hazardous waste management on Fort McCoy, including Fort McCoy tenants. The Commander will:

a. Sign the Hazardous Waste/Material Management Plan.

b. Sign National Environmental Policy Act (NEPA) documentation required for construction of hazardous waste management facilities and ensure that the public involvement procedures of NEPA are followed.

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c. Assign signature authority for certification of the annual Toxics Release Inventory (TRI) report, hazardous waste report, and the Tier Two report.

d. Authorize DPW Environmental Division personnel, who have taken the required training, to sign hazardous waste manifests on behalf of the Army Headquarters Fort McCoy.

2-3. Directorate of Public Works (DPW) The Commander tasks the DPW with oversight of Fort McCoy’s environmental compliance program.

DPW government personnel will:

a. Be the main liaison with federal and state regulators when obtaining RCRA permits, performing required reporting, and for coordinating all issues committing Fort McCoy to expenditures of funds or manpower.

b. Be the main liaison with regulatory agencies for Notices of Violations (NOV) and other enforcement actions.

c. Request adequate funds to implement the hazardous waste management program and avoid/correct hazardous waste related NOV.

d. Identify and justify funds for hazardous waste disposal.

e. Report any notice of non-compliance, enforcement action, or similar activity to the Installation Management Command, Northeast Region (IMCOM-NE).

f. Select appropriate hazardous waste disposal contractors, i.e., use either DRMO or a private company.

2-4. DPW Environmental Division Contract personnel within the DPW Environmental Division perform various operations associated with hazardous waste management and environmental compliance. These include the following activities:

a. Prepare/update the installation Hazardous Waste/Material Management Plan.

b. Complete and submit annual hazardous waste reports.

c. Assist federal and state regulators as requested.

d. Track hazardous waste generation volumes and disposal costs.

e. Research alternative disposal methods, product substitution/process changes, and/or recycling options, including performing associated cost analyses for these options.

f. Provide assistance to on-post hazardous waste generators.

g. Manage and file hazardous waste manifests for waste disposed through private contractors.

h. Obtain signature authority for hazardous waste manifests from the Commander.

i. Sign hazardous and non-hazardous waste manifests on behalf of the United States Army Garrison, Headquarters, Fort McCoy.

j. Ensure that hazardous wastes are received by the facility designated on the manifest.

k. Ensure that off-post transportation of hazardous waste complies with applicable federal, state and local laws and regulations.

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l. Conduct site visits to all hazardous waste generators to ensure compliance with EPA and WDNR regulations.

m. Prepare and submit annual Tier Two, Toxics Release Inventory, and Hazardous Materials Inventory reports.

n. Review all work/service orders to ensure that any resulting contracts and scopes of services include appropriate provisions for the management and disposal of hazardous wastes.

2-5. Directorate of Logistics (DOL) Transportation Division

a. Ensure hazardous materials shipments for support activities comply with applicable regulations. This does not include hazardous materials or wastes taken off-post by Fort McCoy contractors.

b. Provide advice for supported activities regarding hazardous materials shipping requirements.

2-6. Defense Reutilization and Marketing Office (DRMO) Currently, DRMO, through its Fort McCoy office (DRMO-Sparta), is responsible for the reuse, resale, or disposal of excess government property, with the exception of certain waste streams e.g., scrap metals, solid waste, lead-acid batteries, etc. The DRMO-Great Lakes office currently contracts for hazardous waste disposal for Fort McCoy. DRMO, through its contractor, has the responsibility for the following:

a. Developing alternatives to waste disposal and increasing recycling options.

b. Processing turn-in documents.

c. Accepting hazardous property.

d. Signing, filing and routing delivery orders to the disposal contractor.

e. Notifying the DPW Environmental Division of all manifest discrepancies.

f. Procuring a waste hauling/disposal contractor.

g. Ensuring that the DRMO waste disposal contractor is complying with applicable shipping and waste disposal requirements/regulations.

2-7. Other Hazardous Waste Contractors On occasion, the DPW Environmental Division or other Fort McCoy tenant organizations contract directly with other hazardous waste shipping and disposal firms i.e., DRMO is not involved. In these instances, the hazardous waste contractor is responsible for the following:

a. Receiving hazardous waste and shipping the waste according to EPA/DOT procedures.

b. Reviewing and signing hazardous waste manifests upon receipt of the waste.

c. Delivering the waste to the designated disposal facility.

d. Ensuring safe and environmentally-compliant disposal of the waste.

e. Following other terms and conditions of their contracts.

f. In the event that the hazardous waste contractor hires a subcontractor, the contractor is responsible for ensuring that its subcontractor complies with this plan and applicable waste management/disposal regulations. It is important to note that regardless of how hazardous waste is disposed, only the

Fort McCoy Regulation 420-25 September 2009 8 individuals with approved signature authority may sign manifests for hazardous wastes leaving Fort McCoy, see section 6-3.

2-8. Hazardous Waste Generators

a. Many organizations and activities generate hazardous waste at Fort McCoy. It is the hazardous waste generator’s responsibility to properly manage their hazardous materials and hazardous waste storage areas in accordance with the requirements of this plan. See section 4 for a detailed description of hazardous waste storage management standards. Hazardous waste generators are also responsible for providing appropriate information to the DPW Environmental Division for disposal of their wastes. Table 5-1 provides general guidance for the disposal of common waste materials that are generated at many locations at Fort McCoy.

b. For hazardous waste generators that use contractors for the disposal of their wastes, these contracts must be written to include appropriate provisions for the transfer of liability to the contractor once they receive the wastes. Under RCRA, the hazardous waste generator maintains ultimate responsibility for the environmental liability of disposed wastes, unless otherwise specified in the contract.

Therefore, the waste generator must ensure that the disposed materials are handled appropriately by the contractor. Also, as described above, regardless of how hazardous waste is disposed, only the individuals with approved signature authority may sign manifests for hazardous wastes leaving Fort McCoy, see section 6-3.

2-9. Directorate of Plans, Training, Mobilization, and Security (DPTMS) DPTMS provides information to units training on-post through the "Sustainable Range Program Customer Support Package". The package contains general environmental information, including procedures for the turn-in of hazardous and non-hazardous waste, hazardous materials/waste storage procedures, and spill response procedures. DPTMS inspects training areas after use and reports any abandoned wastes to the DPW Environmental Division. Abandoning hazardous waste on Fort McCoy is a violation of Federal and State law.

2-10. Directorate of Emergency Services (DES)

a. Fort McCoy Fire Department

(1) Responds to all hazardous and non-hazardous materials/waste spills or other incidents on-post, in accordance with Fort McCoy Regulation 420-28 (Spill Prevention Control, Countermeasure and Spill Contingency Plans).

(2) Turns over responsibility (incident command) to the DPW Environmental Division contractor for spill clean-up once the risks to structures and human health have been mitigated.

b. Security (Fort McCoy Police Department)

(1) When called, the Police Department will cordon off the spill area to prevent unauthorized access to the affected area during a spill incident.

(2) Routinely patrol the 90-day hazardous waste storage facility.

(3) Investigate all incidents of abandoned hazardous waste.

2-11. Installation Safety Office (ISO) The Installation Safety Office has the following responsibilities related to hazardous materials/waste management:

a. Ensure that installation operations and activities are conducted in compliance with the Occupational Safety and Health Act (OSHA) requirements.

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b. Monitor the storage, packaging, treatment, transportation, and disposal of all radioactive waste.

c. Ensure that post personnel have all training required by federal, state, and Army regulations for the handling and disposal of hazardous materials/wastes. The Mission and Installation Contracting Command or individual organizations that have procured contractors are responsible for ensuring that contractors/employees have the appropriate training and certifications.

2-12. Mission and Installation Contracting Command (MICC) The MICC procures contractors to perform certain projects or functions at Fort McCoy. However, scopes of work for these contracts are typically provided to the MICC by the organizations responsible for the project/service. Thus, these organizations are responsible for ensuring that appropriate hazardous materials/waste management procedures and training requirements are included in these scopes of work.

The MICC is responsible for suspending a contract or taking actions against a contractor if the contractor violates applicable contractual requirements, including hazardous waste requirements.

2-13. Installation Legal Office (ILO) The ILO reviews permit applications, any enforcement actions from regulators, and other legally binding documents. The Legal Office also interprets the various laws and regulations related to hazardous waste management. Prior to obtaining the Commander’s signature, the Legal Office also reviews various annual reporting documents.

2-14. Public Affairs Office (PAO) PAO is Fort McCoy's official spokesperson and briefs the media during a hazardous spill incident and enforcement action. PAO also publicizes successes in hazardous waste minimization and education programs.

2-15. Resource Management Office, (RMO) Program Budget Division The Budget Division within the RMO ensures all hazardous waste disposal costs are paid from the appropriate accounts.

2-16. Contact Phone List Table 2-1 lists pertinent hazardous waste contacts and phone numbers. As required by Fort McCoy Regulation 420-28 (Spill Prevention Control, Countermeasure and Spill Contingency Plan), all spill incidents of one gallon or more are to be reported immediately to the Fort McCoy Fire Department by dialing 911 using a Fort McCoy landline. Cell phone users should utilize the Fort McCoy Police Dispatch number shown in Table 2-1 below.

Table 2-1

Organization Phone Number DPW, Environmental Division (608) 388-2160

DRMO (608) 388-3685

DPW, Natural Resource Branch (608) 388-4793 DES, Fire Department 911 or 388-2508 DES, Security (Fort McCoy Police) 911 or 388-2266 Installation Safety Office (608) 388-3403 ECS, 3050 W. N Street, (88th RRC; B3050) (608) 388-2009 RMO, Program Budget Section (608) 388-3808 Fort McCoy Public Affairs Office (608) 388-4209 MATES, 242 E. G Street (WI Army National Guard; bldg. 242) (608) 388-3775

Installation Legal Office (608) 388-2165

Fort McCoy Regulation 420-25 September 2009 10

Section 3 Hazardous Waste Minimization The EPA defines hazardous waste minimization as the reduction of the amount of hazardous waste that is generated, treated, stored, or disposed. Waste minimization includes any source reduction or recycling activity undertaken by a generator that results in either:

a. The reduction or elimination of the total volume of hazardous waste generated.

b. The reduction of toxicity of hazardous waste.

c. The reduction of disposables and reuse of materials whenever possible.

3-1. Waste Minimization Regulations The Hazardous and Solid Waste Amendments of 1984 (HSWA) to RCRA require that generators adopt a hazardous waste minimization program [40 CFR 262.41(6) and (7)]. Additionally, the annual hazardous waste report filed with the WDNR also must certify that the installation has an active waste minimization program. In accordance with NR 662.041 (3) (e) (f), large quantity hazardous waste generators are required to report on efforts undertaken during odd numbered calendar years to reduce the volume and toxicity of hazardous waste generated and provide a description of changes in generation volumes in comparison to prior years.

a. Federal facilities are directed under Executive Order (EO) 13423 to minimize hazardous material acquisition and hazardous waste generation volumes. EO 13423 also requires the full implementation of an Environmental Management System (EMS) as the primary management tool to implement all directives within the EO. Fort McCoy is currently in the EMS implementation phase moving toward full conformance with ISO 14001 international standard for environmental business management.

b. Implementation of the above stated EO for US Army facilities is required through the US Army regulations and Department of Defense Instructions. Army Regulation (AR) 200-1 requires installations to establish pollution prevention (P2) programs and to develop affirmative procurement programs.

3-2. Fort McCoy Hazardous Waste Minimization Goals Fort McCoy’s goal is to minimize hazardous waste generation to the extent practicable, keeping in mind that mission activities and requirements will influence the amount of hazardous waste generated. Figure 3-1 depicts hazardous waste volume reductions due to past and present waste minimization activities.

Although a significant increase is shown in 2004, this is largely attributable to the disposal of spent aluminum oxide blast media from the former system as well as the temporary blast booth used during construction of the closed loop water blast system.

Fort McCoy Regulation 420-25 September 2009 11

Figure 3-1

3-3. Fort McCoy’s Current Waste Minimization Activities

a. DPW Recycling Contracts: DPW currently has contracts in-place for the recycling of various materials, including spent petroleum cleanup materials (floor dry, spill pads, and spill socks) fluorescent light bulbs, lead-acid batteries, various re-chargeable batteries (NiCd, Lithium etc.) antifreeze, spent ammunition casings (brass) food grease, printer cartridges and scrap metals. Concrete derived from demolition projects is stockpiled and crushed to ¾” gravel for re-use at the installation. Wood wastes are being recycled through the current solid waste contract.

b. DRMO Recycling Contracts: DRMO handles contracts for the recycling of used oil (including waste JP8 and diesel) electronic equipment, various batteries, and tires.

c. Contaminated Soil Disposal: Fort McCoy disposes of POL-contaminated soil through the solid waste contract. The treatment process utilizes microorganisms to degrade (remove) petroleum hydrocarbons present in the soil prior to use of the remediated soils as landfill daily cover material.

d. Alternative Parts Cleaning Operations: Many of the shops at Fort McCoy utilize high pressure, hot water parts cleaners. This equipment replaces older solvent based parts washers. Other shops have switched to parts washing operations that use less toxic solvents i.e., non-chlorinated.

e. X-ray Equipment: The Troop Dental Clinic and Troop Medical Clinic have recently purchased digital X-ray equipment to replace the former film-based equipment that required the use of several hazardous solvents and developing agents.

f. Blast Media Substitution: In past years, aluminum oxide blast media was the primary waste material.

In 2003, this blast media comprised 44% of Fort McCoy's total hazardous waste. During the fall of 2004 a

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Fort McCoy Regulation 420-25 September 2009 12 new blasting system was installed that utilizes high pressure water as the blasting agent. This is a closed loop system and generates significantly less hazardous wastes.

g. Re-Use-It Store: The DPW Environmental Division frequently collects unused hazardous materials at the hazardous waste turn-in facility. Many of these materials are placed into the Re-Use-It Store inventory, where any Fort McCoy organization or training/mobilized unit can obtain the material for free.

The inventory is kept current and publicized to encourage use of these materials. If a material/product is not claimed after remaining in the inventory for a significant period of time, it is then properly disposed.

h. Electronic Equipment Recycling: Some electronic equipment contains precious metals or other valuable materials at potentially hazardous levels. At Fort McCoy, the majority of this equipment is recycled through DRMO. Old electronic equipment can be turned into the DRMO warehouse at 2181 S.

8th Avenue.

i. Ozone-Depleting Chemical Substitution: Fort McCoy completed an Ozone-Depleting Chemical (ODC) Elimination Plan in 2002. ODC refrigerants are being eliminated through refrigerant and/or equipment replacement. Several individuals at Fort McCoy are certified in the proper recovery and handling of ODC refrigerants.

3-4. Fort McCoy's Future Waste Minimization Activities

a. Fort McCoy, through the DPW Environmental Division, is continually evaluating methods and products that can be implemented to further reduce waste and increase recycling efforts. Identification of potential hazardous waste reduction strategies will be accomplished through reviews of the Emergency Planning and Community Right-to-Know Act (EPCRA) required annual hazardous materials inventories supplied by each shop/activity on-post and through the performance of periodic pollution prevention opportunity assessments as necessary.

b. Future hazardous waste minimization efforts will require further reductions in hazardous material use. One method that may reduce hazardous materials use is through further implementation of Green Procurement Program (GPP). This program is currently an “Action Plan” within the installation EMS.

Additionally, the training mandated by this plan will also help to further decrease hazardous materials use and waste generation volumes, see section 8.

c. The on-going EMS implementation process for the installation requires continual identification of environmental aspects and impacts from post activities, including the generation and disposal of hazardous waste. Full EMS conformance to certain elements of the ISO 14001 standard, requires that specific goals and objectives be set to minimize these environmental impacts.

Section 4 Hazardous Waste Storage

4-1. Hazardous Waste Containers Fort McCoy operations that generate hazardous waste must comply with DOT shipping container regulations and the EPA/WDNR hazardous waste accumulation regulations. The DOT regulations are contained in 49 CFR 100-185. These regulations describe container type, vehicle placarding requirements, and emergency notification procedures. Hazardous waste containers must:

a. Be in good condition.

b. Withstand normal handling and extreme temperatures without leaking.

c. Not be creased, rusted, bulged, or seriously dented.

d. Open and close securely.

Fort McCoy Regulation 420-25 September 2009 13

e. Be compatible with the waste contents.

f. Be clearly and accurately labeled with current contents.

g. Have old markings and labels removed or painted to avoid confusion about the contents.

h. Not be filled to the top if the container holds liquids or liquid mixtures i.e., sufficient headspace must be available for expansion. The following chart provides a guide for the amount of headspace that should be left in a “full” liquid container. Containers used for solids do not require specific headspaces, but must easily close without interference from the waste.

Table 4-1 Size of Container Amount of Headspace

55 gallon 5 inches 30 gallon 4 inches 15 gallon 3 inches Less than 15 gallon 2 inches

4-2. Empty Containers Containers that previously held a hazardous waste are exempt from RCRA regulations if they meet the definition of "empty". An empty container is defined as follows per 40 CFR 261.7:

a. For acute hazardous waste or P-Wastes, the container or inner liner has been triple rinsed using a solvent capable of removing the waste.

b. A compressed gas container whose internal pressure is equal to atmospheric pressure.

c. Pumped or poured until no free flowing liquid remains in the container.

d. For containers less than 119 gallons, no more than 2.5 centimeters (1 inch) of residue or 3%, by weight, of the total container capacity remains in the container.

e. For containers greater than 119 gallons of an acute hazardous waste, no more than 0.3% of the product by weight, of the total container capacity remains in the container.

f. The inner liner of a container has been removed and disposed and did not show any evidence of leaks or tears.

4-3. Types of Hazardous Waste Generators Hazardous waste generators are classified by the amount of waste they generate in a given time. These classifications are:

a. Large Quantity Generators (LQG) generate more than 2,200 pounds of hazardous waste in a calendar month.

Fort McCoy is currently classified as a LQG. Per NR 662, LQG can store waste on site for 90 days. The WDNR may grant 30-day extensions under special circumstances. LQG must also have a formal employee training program and complete annual hazardous waste reports. These requirements are further described in the following sections.

b. Small Quantity Generators (SQG) generate between 220 and 2,200 pounds of hazardous waste in a calendar month.

c. Very Small Quantity Generators (VSQG) generate less than 220 pounds of hazardous waste in a calendar month.

Fort McCoy Regulation 420-25 September 2009 14

4-4. Hazardous Waste Accumulation Points and Satellite Accumulation Points

a. Accumulation Points: (AP) are areas where hazardous waste can be stored for up to 90 days. There is no limit regarding the amount of waste that can be stored at AP. On or before reaching the 90 day limit, generators must transport the hazardous waste to a permitted disposal facility. AP regulations can be found within 40 CFR 262 and 264. 207 East G Street is the only AP at Fort McCoy. AP must meet the following requirements:

(1) Containers must be maintained in good condition and marked with the accumulation start date.

Containers of hazardous waste must be marked with the words "Hazardous Waste". Prior to shipping, each container must also be marked with the proper DOT shipping name.

(2) Waste must be stored in compatible containers.

(3) Containers must be inspected weekly to ensure that they are labeled correctly, closed securely and not leaking.

(4) A written inspection log must be maintained for three years.

(5) Fire extinguishers and spill control equipment must be readily available. Fire extinguishers must be inspected monthly.

(6) A copy of Fort McCoy's Spill Prevention Control, Counter measure and Spill Contingency Plans, Fort McCoy Regulation 420-28, must be available. Summarized spill response procedures should be posted by each phone.

(7) A copy of this Hazardous Waste Management Plan must be available.

(8) Sufficient room must be available for safe working.

(9) AP employees must have up-to-date hazardous waste management training in accordance with EPA/OSHA requirements, see section 8.

(10) Containers holding ignitable or reactive waste must be stored at least 50 feet from all property boundaries.

(11) Incompatible…