ATT_05_FK_EnvironmentaL_Handbook_2020_Edition.pdf

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Fort Knox, Ky Consolidated Construction Multiple Award Task Order Contract (MATOC)/Job Order Contract (JOC)
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W9124D20R0034
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This document summarizes a federal contract opportunity for construction services at Fort Knox, Kentucky. The Mission and Installation Contracting Command at Fort Knox plans to solicit offers on June 22, 2020 for a combined Job Order Contract and Multiple Award Task Order Contract to provide maintenance, repair, and minor construction of buildings, structures, and other real property at Fort Knox. The indefinite delivery/indefinite quantity contract will have a broad scope of work to meet a range of facility requirements. The solicitation number is W9124D20R0034 and the contracting agency is the Department of the Army Materiel Command Mission and Installation Contracting Command at Fort Sam Houston.

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Text version

ISSUE 020 VERSION 01

ENVIRONMENTAL HANDBOOK Issue 020 Ver. 01

Fort Knox Environmental Handbook Published by the Fort Knox Environmental Management Division

125 6th Avenue Fort Knox, KY 40121 Office 1-502-624-3629 Fax 1-502-624-3000

EMD Website:

https://home.army.mil/knox/index.php/about/Garrison/directorate-public-works/environmental-management-division

EMD Information emails:

Army.Knox.EMD@Mail.mil https://home.army.mil/knox/index.php/about/Garrison/directorate-public-works/environmental-management-division

SECTION 1

TABLE OF CONTENTS

Fort Knox Environmental Policy Memo 5 Preface 7 Regulatory References 8

SECTION 2 – EMERGENCY INFORMATION 9

Emergency Phone Numbers 9 Environmental Points of Contact (POC) 10

SECTION 3 – RESPONSIBILITIES-UNITS, EOs, OTHERS 11

Tenants, Units and Contractors 11

Environmental Officer (EO) Training 12 Sample Orders for Appointment of EO 14

Environmental Officer (EO) Responsibilities 15

SECTION 4 – OPERATIONAL CONTROLS “How to Pages” 17

Absorbents (Used for POL)

Aerosol Cans

Asbestos (Building Renovation/Maintenance/Demolition)

Brake Pads/ Shoes (Disposal of Unserviceable Brake Shoes)

Ballasts, Capacitors, and Other Equipment Containing PCBs

Batteries (Lead Acid)

Batteries (Non Lead Acid)

Bulk Storage Containers (BSCs)

Compressed Gas Cylinders (CGC)

Construction/Demolition Debris (C/DD) Landfill

Dig Permit/Utility Locate (Cantonment and Training Areas)

Sample Request for Dig Permit Drip Pads/Drip Pans

Fluorescent Tubes and Mercury Containing Lamps

Freon and Ozone Depleting Substances (ODS)

Freon Refrigerant (ODS) Return Policy

Gas Cylinders (Disposable)

Gray Water

Grease (Maintenance)

Hazardous Materials (Procurement/Storage Procedures)

Lead Containing Painting (Surface Preparation-Renovation)

Mold

NBC Equipment (Detector/Decon Kits)

Oil Water Separator (OWS)

Paint & Paint-Related Material (Oil-based Paint and Stain)

Latex (Water-based Paint and Stain)

Parts Washers/Solvent Tank

Pesticides, Herbicides, Rodenticides 44

Petroleum, Oil and Lubricant (POL) Filters 45 Pressure Cleaning Equipment 46 Rags 47 Range/Field Practices 48 Satellite Accumulation Area (SAA) Universal Waste Collection Area (UWCA) 49 Stormwater Best Management Practices (BMPs) Construction Sites 50 Spill Response Materials 51 Tires 53 Vehicle Maintenance 54 Wash Racks 55 Water Purification Operations 56 Weapons Cleaning Materials 57

SECTION 5 - APPENDICES

Appendix A Bulk Storage Containers (BSCs) & Fort Knox

Spill Prevention Control and Countermeasures Plan (SPCCP) 58 Appendix B Environmental Compliance Forms 64 Appendix C Hazardous Materials Management & Minimization 73 Appendix D Hazardous/Universal Waste Guidance 75 Appendix E National Environmental Policy Act (NEPA) 82 Appendix F Natural Resources 85 Appendix G Pollution Prevention & Green Procurement 89 Appendix H Qualified Recycle Program (QRP) 93 Appendix I Spill Prevention and Emergency Response Procedures 100 Appendix J Stormwater/Ground Water Pollution Prevention/

Best Management Practices Plan (SWGPP/BMP) 104 Appendix K Solid Waste Management 108 Appendix L Demand Maintenance Order 111 Appendix M Acronyms 112

Section 1

PREFACE

Ever changing environmental regulations have complicated many of the routine activities that are performed on this installation on a daily basis. These environmental regulations have a significant impact on the way that these "routine activities" are performed. To understand all the requirements from all the regulations would be a monumental undertaking. Environmental stewardship is equally important in both the tactical and Garrison environments. Prevention of pollution, corrective actions and continual improvements are the goals to achieve a sustainable installation. Executive Order (EO) 13834, Federal Leadership in

Environmental, Energy, and Economic Performance (May 2018) expands on the energy reduction and environmental performance requirements for Federal agencies previously identified in EO 13423. The goal of EO 13834 is "to establish an integrated strategy towards sustainability in the Federal Government and to make reduction of Greenhouse Gas Emissions (GHG) a priority for Federal agencies."

The Fort Knox Handbook, Issue 020 – Ver. 01, replaces all previous editions of the Environmental

Handbook and incorporates the latest changes in environmental regulations and Fort Knox policies. The

Fort Knox Environmental Handbook applies to all units (military), tenants, activities, contractors, and partners in excellence. Please note the new handbook format using “How to Pages” in the section titled

“Operational Controls”. Operational Controls represent the Best Management Practices (BMPs) for all environmental programs at Fort Knox.

REGULATORY REFERENCES

The Fort Knox Environmental Handbook has incorporated the following:

32 Code of Federal Regulations (CFR) Part 651

ALARACT 031/2012 – Army Fire Suppression and Environmental Control System Policy and

Procedures

AR 200-1, Environmental Protection and Enhancement, 13 December 2007-Under Revision

AR 210-190, Post Cemeteries, 16 February 2005

AR 350-19, The Army Sustainable Range Program, 30 August 2005

AR 710-2 Supply Policy

ATP 3-34.5 Environmental Considerations, August 2015

ATP 4-45, Force Provider Operations

Clean Air Act (CAA)

Clean Water Act (CWA)

DA Pam 710-7

DODI 4715.23, October 24, 2016, Integrated Recycling and Solid Waste Management

Environmental Management Division Contract Specifications

Environmental Management System (EMS) Procedures

Executive Order 13834, Efficient Federal Operations, May 2018

Fort Knox Regulation 200-3, Fort Knox Hunting and Fishing Regulations and Procedures, 01 June

Fort Knox Regulation 385-10, the Fort Knox Safety Program, 01 FEB 2018

Kentucky Division for Air Quality Regulations

Kentucky Division of Waste Management Regulations

Kentucky Division of Water Regulations (Kentucky Pollutant Discharge Elimination System

Permit)

Federal OSHA Regulations

Resource Conservation and Recovery Act (RCRA)

TC 25-1, Training Land, 15 DEC 2016

TC 3-34.489, “The Soldier and the Environment”, 8 May 2001

SECTION 2

EMERGENCY INFORMATION

Emergency Phone Numbers (Health and Safety)

Ambulance 911 Emergency 911 Fire Department 502-624-6016/1876

Military Police (MP) 502-624-2111

Range Emergency/Spills 502-624-2125

Emergency Phone Numbers (Environmental)

502-624-8263/8186

502-624-5245

502-624-2072

502-624-8537

502-624-3598 502-624-6581/7877

502-624-2072

502-624-3629/4654

502-624-7373

502-624-4500

502-624-4275/5101/5823

502-624-3692/6598/7300 502-624-5245/3598

502-624-3592 503-624-2125/2135

502-624-8537

502-624-8187

502-624-3692/8187

502-942-6020

502-624-1171

Air and Noise

Asbestos Abatement

Bulk Storage Containers (BSCs) (ASTs)

Underground Storage Tanks (USTs)

Compliance Branch

Cultural Resources

Drinking Water

Environmental Management Division

Fish and Wildlife/Hunt Control

Forestry

Hazardous Materials Control Center (HMCC)

Hazardous/Universal Waste Disposal

Lead Paint Abatement

Pollution Prevention

Range Control

Restoration

Stormwater/Groundwater

Waste Water (Grey Water)

Wastewater Treatment Plant

Demand Maintenance Order

Demand Maintenance Order Email:

usarmy.knox.imcom-atlantic.mbx.dpw-work-orders@mail.mil

ENVIRONMENTAL HANDBOOK Issue 020 Ver. 01 mailto:usarmy.knox.imcom-atlantic.mbx.dpw-work-orders@mail.mil

POST THIS PAGE FOR QUICK ACCESS

Environmental Points of Contact

Environmental Management Division Contact Numbers

Asbestos 502-624-5245

Bulk Storage Containers (BSCs)/(ASTs) 502-624-2072

Clean Air Act /Air Pollution 502-624-8263/8186

Clean Water Act/Stormwater 502-624-8187

Cultural Resources 502-624-6581/7877

Drinking Water Operations 502-942-5008

Drinking Water Program 502-624-2072

Emergency Planning and Community Right-to-Know Act (EPCRA) (Hazardous Materials)

502-624-3598

Endangered Species 502-624-7373

Environmental GIS 502-624-1222

Environmental Management System (EMS) and Pollution

Prevention (P2)

502-624-6057

Environmental Training 502-624-3692/6057

Forestry 502-624-4500

Hazardous/Universal Waste 502-624-3692/6598/7300 Lead Based Paint 502-624-5245

Mold 502-624-5245

Natural Resources 502-624-7368

NEPA 502-624-5174

Noise 502-624-8186

Green Procurement Program 502-624-8263

Qualified Recycle Program (QRP) 502-624-5026/5907/5673

Restoration Program (Land Management) 502-624-8537

Solid Waste Management 502-624-3692

Spill Control and Countermeasure Program (SPCCP) 502-624-2072 Tree Cutting 502-624-4500

Used Oil, Antifreeze and Contaminated Fuel 502-624-5026/5673

Wastewater Treatment Operations 502-926-6020

Wetlands 502-624-7368

Wildlife Biologist 502-624-7373

SECTION 3

RESPONSIBILITIES

Tenants, Units and Contractors

A tenant is an authorized activity located on an installation that is not part of the Garrison organization.

This includes, but is not limited to, military units, the Army and Air Force Exchange Service (AAFES), the Defense Commissary Agency (DeCA), and contractors with activities on post. Tenants will:

a) Comply with installation policies, applicable federal, state, and local environmental laws, regulations, EOs, and overseas Final Governing Standards (FGS).

b) Participate in the installation’s planning, sustainability, and Environmental Management System

(EMS) (Note: Installations should evaluate their liabilities concerning non-governmental tenants to determine whether any of them can be exempted from the installation EMS.

c) Designate a representative to the Environmental Quality Control Committee (EQCC)

(Commander or senior level civilian).

d) Ensure personnel receive required environmental training.

e) Participate in all installation internal and external assessments and audits, to include programming for corrective actions.

f) Identify and coordinate non mission-specific environmental requirements with the GC.

g) Pay environmental fines and penalties resulting from their mission activities.

h) Immediately report spills or releases of hazardous substances to the On-Scene Coordinator (OSC).

Pay or reimburse costs associated with cleanup and spill response if not covered in the standard installations services or the Installation Services Support Agreement (ISSA).

i) Report all instances of non-compliance and notification of enforcement actions to the GC immediately.

j) Ensure that non-DOD hazardous material is not stored, handled, or disposed of on the installation unless approved by the Office of the Assistant Secretary of the Army –Installations & Environment

(OASA)-(I&E), his or her designee, or higher authority.

k) Ensure that all hazardous materials are stored, handled or disposed of in accordance with the installation Hazardous Material Management Program (HMMP), and hazardous materials are processed through the Logistics Readiness Command (LRC) Supply Support Activity (SSA) and Hazardous Materials Control Center (HMCC).

UNIT COMMANDERS

The Commander’s role in environmental sustainment centers on building environmental ethics in personnel by training and counseling them about environmental stewardship and sustainability, leading by example, and enforcing compliance with laws and regulations.

The Commander—

Communicates environmental ethics to assigned personnel while training them to be good environmental stewards.

Develops and sustains a positive and proactive commitment to environmental protection.

Protects the environment during training and other activities.

Trains personnel how to identify the environmental effects of plans, actions, and operations in relation to the mission, environment, community, and fiscal resources.

Trains personnel on the importance of protecting the environment and the possible consequences of noncompliance and non-sustainable practices.

Understands the links between environmental considerations and the associated impacts on Force Health Protection (FHP), safety, and other protection aspects.

Oversees the Environmental Officer’s performance.

Appoints and trains Environmental Officers at appropriate organizational levels to ensure compliance actions take place (see ATP 3-34.5, August 2015, for Environmental Officer

Responsibilities).

NOTE: The word Organization will be used throughout this handbook, which will refer to a military unit, civilian organization, or contractor tenant.

Environmental Quality Control (EQCC)

a) Installations will establish an EQCC chaired by the Garrison Commander (GC). The EQCC will include major and sub-installation tenant activities and contractors. EQCCs will meet at least quarterly and document/decisions.

b) The EQCC should consist of members representing the operational, logistics, engineering, planning, resource management, legal, medical, environmental, Morale, Welfare, and Recreation

(MWR), commissary, exchange service, and safety interests of the command, including military installation tenant activities, and contractors.

c) The EQCC will help to plan, execute, and monitor actions and programs with environmental implications. The committee will identify issues, make recommendations, and advise the GC.

Environmental Officer (EO) Training

Environmental Officer (EO) Training is conducted by the Environmental Management Division (EMD).

AR 200-1 and ATP 3-34.5 requires trained and appointed Environmental Officers from all activities on the installation. EMD prefers to have a primary and an alternate Environmental Officer for each activity.

An EO should be available for a 12 month tenure on Fort Knox. The initial course is 3 days and required once. A 1-day re-certification course is required every year after successful completion of the 3-day course. A certificate and ID card will be issued upon completion of the EO training. Course dates will be posted on the EMD webpage.

Course Topics:

Topics covered may vary from time to time, based on regulatory changes or compliance issues.

Generally, a standard agenda would include, but is not limited to, the following: Clean Air, Asbestos &

Lead, Bulk Storage Containers, Compliance Inspections, Cultural Resources, EMS, EPCRA, General

Information, Green Procurement, Hazardous Materials, Hazardous/Universal Wastes, Natural

Resources, Operational Controls, Pollution Prevention, Recycling, Regulatory Changes, Spill Response, Stormwater, and other subjects as needed. Students are questioned throughout the course and are provided with numerous hands-on experiences to ensure they are competent in the material covered.

Course Registration

You may register for courses by contacting the Environmental Training Officer at 502-624-

3692/6057, or sending an e-mail to: Army.Knox.EMD@Mail.mil, requesting a registration form.

Return the completed registration form and include a copy of your appointment orders. All classes are limited to 30 students.

ENVIRONMENTAL HANDBOOK Issue 020 Ver. 01 mailto:Army.Knox.EMD@Mail.mil

Sample Orders for Appointment of EOs

DEPARTMENT OF THE ARMY

ORGANIZATIONAL NAME/TITLE

STANDARDIZED STREET ADDRESS

CITY, STATE, AND ZIP + 4 CODE

REPLY TO

ATTENTION OF

OFFICE SYMBOL Date

MEMORANDUM FOR SEE DISTRIBUTION

SUBJECT: Appointment of Environmental Officers

1. References: AR 200-1, Environmental Protection and Enhancement, 13 December 2007, ATP 3-34.5, Environmental Considerations, August 2015.

2. Effective immediately, the following individual(s) is/are appointed as the Environmental

Officer(s) for (YOUR UNIT).

a. PRIMARY – Name, Rank/Grade, Phone number and E-mail address

b. ALTERNATE – Name, Rank/Grade, Phone number and E-mail address.

3. Period: Until officially relieved from appointment or by reassignment.

4. Special Instructions:

a. Individual serves as the primary liaison to the Environmental Management Division as outlined in the references above.

b. The Environmental Officer(s) listed above is responsible for complying with the duties outlined in the references above.

Signature Block of the

Commanding Officer or Supervisor

DISTRIBUTION:

Individual(s)

Organization Training Officer

Environmental Officer (EO) Responsibilities

AR200-1

To ensure compliance with Army regulations and federal, state and local regulations, each organization is responsible for the following:

AR200-1 mandates EOs be appointed and on orders.

Appointment Orders - Appointing on orders a primary and alternate Environmental Officer (EO) for all company level and above units. A copy of all appointment orders shall be emailed to EMD at:

Army.Knox.EMD@Mail.mil

Environmental Duties/Positions - The EO for each organization is responsible for all environmental duties/positions. The EO is responsible for maintaining copies of all training records associated with their activities.

EQCS Meetings - The EO or alternate shall attend the monthly Environmental Quality Control

Subcommittee (EQCS) meetings. Meetings are scheduled for the third Wednesday of each month at 0930 hours.

Facilities Inspections - Organizations are responsible for applicable inspections of facilities under their operational control to ensure compliance with environmental laws, regulations, and the Fort Knox

Environmental Handbook. Inspections must be completed in accordance with (IAW) guidance on inspection forms. Inspection reports will be kept on file by the organizations and must be available for subsequent inspections.

Hazardous Waste Coordination - The EO is responsible for hazardous waste coordination, if applicable.

The EO may appoint any number of personnel to assist in the handling of hazardous waste. However, the

EO is responsible for ensuring that these personnel receive familiarization training provided by EMD within 120 days of becoming a hazardous waste worker, if applicable. Hazardous Waste Training can be obtained by either attending the 3-day or 1-day recertification course or from EMD Hazardous Waste personnel.

Solid Waste and Recycling Officer - The Solid Waste and Recycling Officer position is considered to be part of the EO’s job duties as well. However, the EO may appoint other personnel to assist with these duties.

Spill Prevention Control and Countermeasures Plan (SPCCP) - Each organization will use the current

Fort Knox Spill Prevention Control & Countermeasures Plan which is available on the EMD webpage.

EMD has a standard SPCCP form for use by short term contractors. See Appendix A for contractor SPCCP form and Emergency Notification template.

ENVIRONMENTAL HANDBOOK Issue 020 Ver. 01

Stormwater/Ground Water Pollution Prevention and Best Management Practices - The EO is also responsible for Stormwater and Groundwater Pollution Prevention and Best Management Practices implementation, if applicable. However, the EO may appoint other personnel to perform these tasks. All appointed personnel shall be on orders with a copy furnished to EMD. See Appendix J.

Stormwater/Ground Water Pollution Prevention/Best Management Practices.

Training Records - Units/Activities/Tenants/Contractors should retain the following records:

Environmental Officer Certification and ID Card: (Primary and Alternate)

Unit Environmental Awareness Training

Spill Response Training

If you have questions, please call the Environmental Management Division (EMD) at 502-624-

3629 or e-mail your question to: Army.Knox.EMD@Mail.mil

ENVIRONMENTAL HANDBOOK Issue 020 Ver. 01

SECTION 4 - OPERATIONAL

CONTROLS

BEST

MANAGEMENT

PRACTICES (BMPs)

ABSORBENTS

Pads, Towels, Booms, Rags and Dry Sweep

401 KAR 31, 32, 33 and 40 CFR 260-262

Absorbent material saturated with petroleum, oils and lubricants (POL) that may be disposed of improperly, or potentially contaminate ground water.

Absorbent materials contaminated with POL are considered non-hazardous waste. Any materials other than POL, may be considered a Hazardous Waste. Contact EMD at 624-3692/6598/7300.

Step 1 Wear proper personal protective equipment

(PPE) listed on the safety data sheet (SDS).

Step 2 Bag contaminated absorbent materials.

Step 3 Take contaminated material to the C/DD landfill and deposit in the contaminated soil container.

NOTE:

If absorbent material (placed in plastic bags) is contaminated with POL, it must be disposed of at the Construction/Demolition and Debris (C/DD) landfill located on Baker Road, in the proper contaminated soil/absorbent dumpster

Call EMD at 502-624-3692/6598/7300 if you clean up anything other than POL. EMD will provide guidance for proper disposal. See Appendix D and K.

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES

GENERAL INFORMATION

AEROSOL CANS

401 KAR 31, 32, 33 and 40 CFR 260-262

Aerosols are under pressure and may contain hazardous chemicals. Disposal of aerosol cans will only be handled by the Hazardous Waste section.

Aerosol cans that are no longer needed or unserviceable (e.g., broken nozzle), but are still under pressure and/or still contain chemicals, must be collected and turned in at the hazardous material collection connex for proper disposal or reuse.

Step 1 Aerosol containers must be stored in a flammable storage cabinet/connex.

Step 2 Ensure aerosol cans are properly labeled to identify contents, remove the barcode label and turn-in the label to the HMCC.

Step 3 Turn in empty and unusable aerosol cans to the hazardous material collection connex. See

Appendix D for guidance.

NOTE: Only national stock numbered (NSN) items that are in original unopened depot packaging, and have not expired, will be accepted at the HMCC.

Contact EMD at 502-624-3692/6598/7300 for additional information. See Appendix D.

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES

Hazardous materials collection connex

GENERAL INFORMATION

ASBESTOS

Building Remodeling/Maintenance/Demolition

40 CFR Part 61, Subpart M and 401 KAR 58

Asbestos may be found at any building on the installation. There is an increased health risk associated with improper handling procedures. Piping, floor tile and insulations may contain asbestos.

Asbestos-containing materials are managed as regulated wastes by EMD accredited personnel.

Step 1 Contact EMD at 502-624-5245 to schedule an inspection. EMD personnel will make a determination for removal and/or disposal.

Step 2 EMD personnel will complete the forms and reports used for asbestos removal and disposal.

Step 3 All asbestos abatement and removal is handled through initiation of a DA 4283 or Demand

Maintenance Order. See Appendix L.

Step 4 Maintain Demand Maintenance Order number(s) to monitor status.

NOTE:

A. Activities such as sanding, grinding, drilling, or sawing of asbestos-containing materials are prohibited by OSHA. Only trained and certified abatement workers may disturb or remove asbestos materials.

B. The removal of asbestos requires a regulatory notification to the Kentucky Division for Air

Quality, which is submitted by the Asbestos

Coordinator.

For additional information contact EMD at 502-624-5245. See Appendix L.

CHARACTERIZATION

HANDLING PROCEDURES

GENERAL INFORMATION

POSSIBLE AREAS OF CONCERN

BRAKE PADS/SHOES

Disposal of Unserviceable Brake Shoes

40 CFR § 763,401 KAR 58, 29 CFR § 1910.1001 (f)(3)

Some brake shoes/pads or clutch disks may contain asbestos-containing materials or other harmful elements.

OSHA requires special handling procedures when disturbing brake pads/shoes as they may contain harmful dust.

Step 1 Brake shoes, pads and clutch disks must be wetted when being disturbed or handled. Do not use compressed air to remove dust from brake components.

Step 2 Double wrap brake shoes/pads or clutch disks in 6 mil or thicker plastic, seal with duct tape and place in a sturdy, closed container. Do not exceed 20 pounds per package.

Step 3 Brake pads/shoes that have been wetted and wrapped in plastic can be placed in the scrap metal collection bin, or taken directly to the Recycle Center.

Step 4 Contact EMD for additional guidance or for testing of brake components that are suspect to contain asbestos.

NOTES:

A. Personnel must wear proper Personal Protective Equipment (PPE) when disturbing material that possibly contains asbestos.

B. The dust from used brake pads/shoes and clutches may contain other harmful elements, and all safety precautions should be considered when dealing with the materials.

C. The US EPA encourages recycling of brake pads/shoes that do not contain asbestos.

D. EMD has conducted numerous tests of used brake pads/shoes and none of the laboratory results indicated asbestos levels below the OSHA Permissible Exposure Limit (PEL) of 0.1 f/cc.

For additional information contact EMD at 502-624-5245.

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES FOR MILITARY & CIVILIANS ON POST

GENERAL INFORMATION

ENVIRONMENTAL HANDBOOK Issue 020 Ver. 01 robert.trail Sticky Note Should it read "laboratory results indicated asbestos levels above the OSHA Permissible Exposure Limit"...?

BALLASTS, CAPACITORS & OTHER

EQUIPMENT CONTAINING PCB’S

401 KAR 31, 32, 33 and 40 CFR 260-262

Polychlorinated Biphenyls (PCBs) are a major type of toxic chemical. They are a potential carcinogenic and exert a multitude of serious adverse health effects.

PCBs are most commonly found in electrical transformers and capacitors, air conditioning equipment and lighting ballasts.

Step 1 Non-routine (not daily maintenance operations) building and facility maintenance and building renovation or demolition require that all ballasts and capacitors are removed and properly disposed.

Step 2 Contact EMD at 502-624-3598/6598/7300 to get guidance on an approved disposal process.

NOTES:

A. Routine/daily on-post maintenance activities will collect ballasts and capacitors and place in a properly marked container provided by EMD.

B. Activities are not authorized to sign a hazardous waste disposal manifest. All Hazardous Waste manifesting must be coordinated through EMD.

Ballasts and Capacitors may contain PCB’s

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES

ENVIRONMENTAL HANDBOOK Issue 020 Ver. 01

Contact EMD at 502-624-3692/6598/7300 for additional information.

GENERAL INFORMATION

BATTERIES (Lead-Acid)

The cells of a lead-acid battery contain lead, lead dioxide, and an acidic electrolyte solution of sulfuric acid. The electrolyte is a strong corrosive agent. Batteries may also vent explosive hydrogen gas.

Lead acid batteries are hazardous due to their lead content and corrosiveness. It is illegal to dispose of a lead acid battery in a landfill. Do not place in trash container

Step 1 Establish a battery program through your Supply Support Activity (SSA) office.

Step 2 Batteries should be stacked no more than two tiers high on a spill containment pallet with cardboard in between (do not drain electrolyte).

Step 3 Personnel must have proper PPE, spill clean-up material on-hand, and be properly trained to address any spills.

Step 4 New and used batteries must be stored in designated areas on spill containment pallets.

Store in an area that provides protection from the weather.

Step 5 QRP can take all government NSN lead acid batteries with the exception of the following:

NSN 6140-01-390-1968 TAKE THESE

NSN 6140-01-390-1969 BATTERIES TO

NSN 6140-01-446-9506 HMCC

NOTES:

A. Damaged batteries must be double-bagged prior to turn-in (i.e., exterior case cracked). Store damaged batteries separate from serviceable batteries and contact the EMD hazardous waste section for disposal procedures.

B. Battery terminals must be taped or capped when turning in to the QRP or EMD Hazardous Waste section. If batteries are to be stacked, they must be on a pallet with cardboard placed between layers.

Stack batteries two layers high only

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES

ENVIRONMENTAL HANDBOOK Issue 020 Ver. 01

Contact EMD at 502-624-3692/6598/7300 for additional information.

GENERAL INFORMATION

BATTERIES (Non Lead-Acid) (Universal Waste)

401 KAR 31, 32, 33 and 40 CFR 260-262

Lithium, Lithium-Ion, Nickel-Cadmium, Magnesium, NiCad (wet), Mercury, Nickel Metal Hydride and rechargeable batteries have chemicals that are a concern during routine use and disposal, and may contaminate the environment.

All Lithium, Lithium-Ion, Nickel Metal Hydride, Nickel-Cadmium, Magnesium and Mercury batteries are Universal Waste. As a best management practice, all batteries will be collected as used batteries and waste determinations will be made by EMD personnel.

Step 1 Unit/activity will turn-in non-lead acid batteries to the EMD Hazardous Waste

Section.

Step 2 If a unit/activity has the need for a Universal

Waste Collection area, EMD will establish the area, provide the proper container(s), labels, and training.

Step 3 All containers must be labeled to identify their contents and the top must be closed when not adding batteries.

Step 4 The used batteries container will be picked up by EMD personnel and EMD will provide a replacement container.

Step 5 ALL Batteries must have the terminals taped PRIOR to turn-in or pickup.

Lithium, Nickel-Cadmium (NiCad), are Universal Waste.

Contact EMD at 502-624-3692/6598/7300 for additional information.

GENERAL INFORMATION

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES

BULK STORAGE CONTAINERS (BSCs) 55 Gallon or Larger Drums/Tanks

40 CFR 112

Bulk Storage Containers (BSCs) require proper monitoring of the structural integrity and/or the interstitial space to prevent tank failure.

Corrosion may weaken the structural integrity and lead to leaks and/or spills, creating a potential threat to the environment.

Step 1 55 gallon and larger containers are kept in secondary containment.

NOTE: Secondary containment should be equal to the container plus 10%.

Step 2 Site personnel will conduct monthly inspections on all 55 gallon and larger containers (inside and outside) using form EMD5058. See Appendix B.

Step 3 Maintain adequate spill materials at BSC area.

Step 4 Conduct inspections on open secondary containment after rainfall events to determine if the collected water has an oily sheen and document your findings (contact EMD at 502-

624-8187 for guidance).

Step 5 Clean the secondary containment as needed.

DRUMS Stored Outside of HAZMAT SHEDS

Step 1 Ensure that drums 55 gallon or larger are stored on secondary containment and protected from inclement weather.

Step 2 Place drums under shed roofs on containment pallets or in secondary containment.

Step 3 Conduct monthly inspections of all drums using EMD 5058 found in Appendix B.

NOTE: Fort Knox recommends the use of double-wall tanks.

Contact EMD for additional information at 502-624-2072.

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES

GENERAL INFORMATION

COMPRESSED GAS CYLINDERS (CGC)

401 KAR 31-33 and DLAI 4145.25

Oxygen, acetylene, argon and other pressurized bottles have hazards associated with fire and pressurized containers.

Refillable compressed gas cylinders are used for both civilian and military operations. Compressed gas cylinders are stored, handled, and disposed of in accordance with DLAI 4145.25.

GOVERNMENT OWNED

Step 1 All Government Owned cylinders are to be returned to the Defense Supply Center Richmond (DSCR).

Contact Hudson Technologies at (866) 724-0932 or via email at cylreturn@hudsontech.com.

Step 2 All cylinders and cylinder information shall be listed on a tracking spreadsheet sent to HudsonTech. An example of this spreadsheet can be found in Appendix

B.

Step 3 Storage requirements should be IAW DLAI 4145.25 and coordinated with the Fire Department and

Installation Safety Office.

Step 4 Commercially Owned Compressed Gas Cylinders are to be returned to the vendor.

NOTES:

A. Medical oxygen cylinders are issued and exchanged at Ireland Army Health Clinic supply section.

B. Small Carbon Dioxide or Nitrogen cylinders with no valves should be considered empty when fully discharged.

C. For compressed gases and cylinders for all Fire Suppression Systems (FSS) and air-conditioning and refrigeration (A/C) systems installed in Army weapon systems or equipment, review

ALARACT031/2012.

D. DRMS may not accept physical custody of any cylinders, unless rendered scrap.

E. DRMS may accept accountability of non-hazardous or hazardous cylinders on behalf of the activity reporting the excess cylinders. See DRMS-1-4160-14, Section 3 - Special Processing.

See Appendix B or contact EMD for additional guidance at 502-624-8263

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES

GENERAL INFORMATION

ENVIRONMENTAL HANDBOOK Issue 020 Ver. 01 mailto:cylreturn@hudsontech.com

CONSTRUCTION/DEMOLITION DEBRIS (C/DD)

401 KAR 47 AND 48 and FORT KNOX REGULATION 200-2

Potential environmental impacts associated with the land-filling of C/DD debris are groundwater, water and air pollution. A growing concern involves the environmental impacts linked with the disposal of pressure-treated lumber. DoD Sustainable Management of Waste in Military Construction, Renovation and

Demolition Activities can minimize the potential negative environmental impact while achieving mandatory waste reduction goals.

Only non-hazardous C/DD debris that cannot be reused or recycled can be taken to the installation’s C/DD

Landfill. Materials containing regulated constituents cannot be disposed of in the C/DD Landfill. Contact

Contact EMD at 502-624-3692 for clarification on C/DD waste.

Step 1 Contractors must develop and submit a

C/DD Waste Management Diversion

Plan (must achieve 60 % diversion) for approval by general contract COR.

Contractors must evaluate all diversion options and make good-faith effort to achieve the highest diversion rate within the project schedule and budget.

Step 2 Submit weights generated by reusing, salvaging, returning or recycling to

EMD Compliance once a month and upon the completion of the contract.

C/DD material segregated for recycling

GENERAL INFORMATION

Contact EMD for more information at 502-624-3692.

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES

DIG PERMIT/UTILITY LOCATE

Cantonment and Training Areas KRS 367.4901 to 367.4917 and AR 420-1

Call 811 prior to digging

Failure to locate underground utilities (water/sewer, electric, gas, phone, steam/chill water, control cables, petroleum/POL, cable TV) and environmental/historical sensitive areas (archeological sites, former solid waste disposal sites) can cause dangerous situations to personnel and the environment.

Additional information can be found in Army Regulation AR 420-1.

UTILITY LOCATIONS are required before any digging, excavation, or earthwork is performed within the cantonment or training areas. All utilities must be properly marked. Digging may create erosion issues. This applies to all organizations performing excavation of soil within the Fort Knox cantonment area and/or training areas.

Step 1 Contact the EMD NEPA Manager at 502-624-5174, 10-15 days prior to starting work.

Step 2 CALL 811 or 800-752-6007. Requests MUST be initiated within 10 working days before excavation is to begin.

Step 3 CALL DPW at 502-624-1171 for gas, water, or sewer connects.

Step 4 In addition you must call;

Natural Gas - 502-624-5954 for gas lines

NEC at 502-624-3338 for POST telephone lines

Cultural Resources (Historical) at 502-624-6581

Restoration Office at 502-624-8537

Natural Resources (Forestry) at 502-624-7368

Range Control (Training Areas) at 502-624-3536

Knox Hills 502-799-6565

Step 5 Survey information must be verified by all agencies in step 4 prior to any digging.

American Public Works Association

(APWA) Color Code Chart

NOTE: Range Excavations: you must submit a memorandum to Cultural Resources. See next page for

Request for Dig Permit - Sample Memorandum

Contact EMD for additional information at 502-624-5174.

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

GENERAL INFORMATION

HANDLING PROCEDURES

US ARMY INSTALLATION MANAGEMENT COMMAND

HEADQUARTERS, US ARMY GARRISON COMMAND, FORT KNOX

199 6th AVENUE SUITE 333

FORT KNOX, KENTUCKY 40121-5719

OFFICE SYMBOL 11 September 2017

REPLY TO

ATTENTION OF: MEMORANDUM THRU Directorate of Public Works (DPW), Environmental

Management Division (EMD), Archaeology/Cultural Resources, Attn: IMKN-PW-R Fort Knox, KY 40121

FOR Directorate of Plans, Training, Mobilization and Security (DPTMS), Attn: IMKN-PLT-R, Range Branch, Fort Knox, KY 40121

SUBJECT: Sample Request for Dig Permit (Range and Training Area Complex)

1. Units seeking to dig within the Fort Knox range and training area complex must submit a memorandum through Cultural Resources to Range Branch 30 days prior to the requested start date of training. The memorandum will include the following:

a. Provide the primary POC responsible to coordinate all aspects of the digging operation to include responsibility to fill in all excavations at the completion of training.

b. Describe what it is you want to dig (i.e. individual hasty or prepared fighting positions, heavy weapon fighting positions, vehicle fighting positions, tank ditch, etc.). Also provide the dimensions for each type of emplacement and an approximate number of emplacements to be dug.

c. Provide the date digging will begin (this request should be submitted to EMD/Range at least 30 days prior to training dates).

d. Provide the location where digging activities are requested. Attach a map or drawing of the area depicting a polygon of the area to which digging activities will be contained. Provide an 8 digit grid coordinate for each corner of the polygon and an approximate acreage/square footage of the area to be disturbed.

2. The memorandum must be approved by Cultural Resources, located in building 9297, Room 108 (624-6581), prior to submission to Range Branch. Cultural Resources will forward this memorandum to EMD if there are other issues to be resolved.

JOHN R. DOE

CPT, IN

Commanding

DRIP PADS / DRIP PANS

401 KAR 4, 5 AND 10 and KPDES PERMIT

Petroleum, Oils and Lubricants (POL) can potentially enter stormwater systems and pollute ground water.

Drip pads/pans are placed under leaking vehicles to prevent POL products from contaminating the soil.

Drip pads are designed to captured POL products but not rain water.

Your Command SOP dictates the use of drip pans.

B. Using drip pans creates the potential for spilling oil on the ground or in the storm drains, or not having the proper collection area for oily water. The preferred method for preventing spills is using a drip pad.

C. Remove POL/sheen from drip pan with oil absorbent. Run any oil water mixture through oil water filter/separator. Bag used absorbent/pads and dispose of at C/DD landfill in contaminated soil roll-off.

D. Saturated drip pads should be passed through a pad wringer to remove excess POL, for extended use.

E. Drip pads that can no longer be used must be bagged and disposed of at the C/DD landfill in the contaminated soil roll-off.

Contact EMD for more information at 502-624-8187.

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

Step 1 Place drip pads/pans under leaking vehicles only.

Step 2 Notify your maintenance section to have the vehicle repaired.

Step 3 Drip pads/pans must be checked routinely and after each rain fall event.

NOTES:

Fort Knox does not require drip pans to be used unless:

You have a seriously leaking vehicle (vehicle should be repaired immediately).

You are conducting refueling operations.

HANDLING PROCEDURES

GENERAL INFORMATION

FLUORESCENT & MERCURY-CONTAINING

LAMPS

401 KAR 31, 32, 33 and 40 CFR 260-262

Small quantities of mercury and lead are used to manufacture fluorescent, mercury vapor, metal halide, and high pressure sodium lamps.

Fluorescent lamps and mercury-containing lamps are universal wastes.

Step 1 Place used fluorescent lamps in a container provided by EMD. Lamps must be separated by size and type.

Step 2 Close container after adding a bulb/lamp.

Step 3 Lamps stored at the unit/activity must be in an approved/original container.

Step 4 Small quantities of lamps can be taken to

BLDG 2954 for disposal.

NOTES:

A. Do not discard fluorescent lamps in solid waste dumpsters.

B. Do not leave your lamps outside of the HW offices or building.

C. In accordance with 40 CFR, accumulation of universal wastes cannot exceed one year from the Date in Use (The day the first item is put in the container).

D. Broken lamps are considered a hazardous waste and must be handled and packaged separately. Contact EMD at 502-624-

3598/6598/7300 for guidance.

Contact EMD for additional information at 502-624-3692/6598/7300.

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES

GENERAL INFORMATION

FREON & REFRIGERANTS OZONE

DEPLETING SUBSTANCES (ODSS)

40 CFR Part 82: Subpart B (MVAC), Subpart F (Appliances)

Failure to properly handle refrigerants and other ODSs creates the potential for air pollutants and violation of federal, state, local and Fort Knox regulations.

40 CFR Part 82 requires that all ODS recovery and recycling equipment must be certified to meet EPA refrigerant recovery requirements. Maintenance and/or repair of any stationary refrigerant-containing appliance or Motor Vehicle Air Conditioning (MVAC) shall be done by technicians who have attended and completed an approved Section 608 (appliances) or 609 (MVAC) Technician Training and Certification Program. All refrigerant-containing appliances including refrigerators, window air conditioning units, and water coolers must have refrigerant evacuated from the unit by a certified technician and placarded accordingly before disposal.

Stationary Refrigerant Appliance and ODS Recovery/Recycling Equipment

Step 1 Work on stationary refrigerant appliances is regulated under Section 608 and can only be completed by technicians that have obtained the appropriate EPA certification(s) for the type(s) of unit(s) they maintain. A copy of their certification(s) is maintained on site and available for review by an EPA inspector.

Step 2 For older types of refrigerant recovery machines, make sure to have records that they are EPA certified units. For newer units, ensure that all equipment has a manufacturer’s label indicating the unit meets EPA recovery requirements.

https://www.epa.gov/section608/section-608-technician-certification-0

Appliances- Refrigerant from all appliances (e.g. refrigerators, window AC units, water coolers) must have refrigerant evacuated from unit by Section 608 certified technician before disposal. Technician must apply a placard with signature and when refrigerant removed.

Motor Vehicle Air Conditioning (MVAC) Recovery/Recycling Equipment Step 1 MVAC maintenance and repair is regulated by EPA Section 609 regulations and applies to all government owned and tactical vehicles.

Step 2 Only soldiers/personnel who have obtained Section 609 certification are authorized to operate MVAC recovery or recycling equipment.

https://www.epa.gov/mvac/section-609-technician-training-and-certification-programs

NOTES:

A. All refrigerant and ODS recovery containers must be labeled with the type of refrigerant contained.

B. The intentional venting of refrigerant into the environment is strictly PROHIBITED and can result in criminal prosecution.

For additional information contact EMD at 502-624-8263/8186.

HANDLING PROCEDURES

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

GENERAL INFORMATION

FREON REFRIGERANT (ODS) RETURN POLICY

(Compressed Gas Cylinders)

DoD Turn-in Procedures (May 2018) and DLAI 4145.25 (AR 700-68)

Excess refrigerants: R-11, R-12, R-114, R-500, R-502; Halons; R-22. Failure to properly handle Freon

& refrigerants and ODSs creates the potential for air pollutants and violation of federal, state, local and

Fort Knox regulations.

All excess refrigerants listed above must be turned-in to the ODS Reserve to ensure that refrigerant supplies for mission critical uses are available.

Step 1 Organizations that have cylinders containing excess refrigerant must contact EMD to determine proper disposal procedures.

Step 2 Determine the number of cylinders and type of refrigerant, and whether it is government-owned or vendor-owned cylinders.

Step 3 Send an email to: army.knox.emd@mail.mil with information from Step 2.

Step 4 EMD will determine proper disposition of refrigerant.

NOTES:

A. Storage of these excess containers must be in compliance with DLAI 4145.25.

For additional information contact EMD at 502-624-8263/8186.

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES

GENERAL INFORMATION

GAS CYLINDERS (Disposable) Non-reusable, single-use containers (i.e., Propane, Ether, MAPP, Helium for balloons, etc.)

401 KAR 31, 32, 33 and 40 CFR 260-262

Propane, ether and other pressurized bottles have hazards associated with fire and pressurized containers.

Non-refillable propane and MAPP gas bottles are used for plumbing operations, personal heating and vehicle operations. These gases represent physical and environmental hazards if not disposed of properly.

Step 1 All non-refillable cylinders are to be properly labeled and stored in a flammable cabinet.

Step 2 When disposing of these containers, or turning-in excess, they are to be returned to the hazardous material container connex, located near BLDG 2954.

NOTES:

A. Helium tanks used to fill balloons shall be taken to the

Recycle center, when empty.

B. Ether cylinders are to be handled as a hazardous waste when disposing. However, full cylinders in a complete case that have not expired can be returned to the manufacturer. Contact EMD at 502-624-3692/6598/7300 for guidance on ether cylinders.

C. Personal propane cylinders (used on grills) shall be taken to the PX for exchange or turn in.

Contact EMD for additional guidance at 502-624-3692/6598/7300.

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES

GENERAL INFORMATION

GRAY WATER

401 KAR 4, 5, 10 and KPDES Permit

Improperly handled gray water during field exercises from Mobile Kitchen Trailers (MKTs) and field showers could result in the release of contaminants into the environment, particularly the stormwater and groundwater.

Gray water contains potential environmental pollutants. Digging gray water pits is prohibited at Fort Knox unless it is a training requirement. EMD will issue an authorization for digging gray water pits during training. Visiting units are allowed to bring their own gray water containers to Fort Knox.

Field Exercises

Step 1 Contact EMD at 502-624-8187/3692 or e- mail a request to: Army.Knox.EMD@Mail.mil to request an application for gray water containers.

Step 2 Gray water tanks will be obtained from QRP at 502-

624-5026. You will need a copy of the approved application.

Step 3 Collect gray water from field kitchens, field showers and field laundries.

Step 4 It is the unit’s responsibility to transport gray water to the WWTP. The WWTP operates 24/7 and can be contacted at 502-942-6020.

Step 5 Rinse the gray water tank prior to turn in to

QRP at building 2962.

Gray water tank

Contact EMD at 502-624-8187/3692 for additional guidance.

GENERAL INFORMATION

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES

GREASE (Maintenance)

Grease contains petroleum hydrocarbons and additives which may contaminate the groundwater if improperly disposed. Refer to the SDS for specific hazards.

Grease requires proper handling and disposal to protect the environment and personnel.

Step 1 Grease containers/tubes should be properly labeled from the HMCC, stored out of the weather and protected from direct sunlight or freezing.

Step 2 Used grease tubes, that are completely empty can be disposed of in a solid waste dumpster. All other containers should be turned-in to the hazardous material container connex (near BLDG 2954).

Step 3 When turning in usable grease tubes:

A. They can be taken to the EMD hazardous material container connex (near BLDG 2954).

B. Transferred to another organization on the installation.

NOTE: Contact EMD at 502-624-3692/6598/7300 for disposal instructions of expired or contaminated grease.

Contact EMD for additional information at 502-624-3692/6598/7300

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES

GENERAL INFORMATION

HAZARDOUS MATERIALS

(PROCUREMENT/STORAGE PROCEDURES)

42 USC § 11002, EO 13834, 40 CFR, 29 CFR, AR 710-2, DA PAM 710-7

Failure to report the qualifying chemicals to the proper agencies could lead to regulatory violations.

All organizations are required to process hazardous materials (HM) through the Hazardous Materials

Control Center (HMCC). Organizations should adhere to a 14 day on-hand supply of hazardous materials as required by the organization to accomplish the mission. This allows for annual regulatory reporting in accordance with Emergency Planning and Community Right-to-Know Act (EPCRA) and cradle-to-grave management of hazardous materials.

Step 1: Obtain approval from EMD prior to purchasing new types of HM. (Products that are new to the installation and have never been processed through the HMCC in the past.)

Step 2: Ensure vendor/manufacturer provides a copy of the

SDS with the HM purchased.

Step 3: Ensure all HM is delivered, or taken to the HMCC for processing through the HM database and labeled.

Step 4: Ensure all materials are properly marked to identify contents and stored in accordance with the SDS.

Step 5: When HM has been used, the user must return the label to the

HMCC to adjust the organization’s inventory.

Step 6: Empty/used or excess* HM containers are taken to the HM collection connex near BLDG 2954.

NOTES:

A. All flammable materials and aerosols must be stored in a flammable locker/connex.

B. All corrosive materials must be stored in a corrosive cabinet.

C. Ensure containers are kept closed, and in its original container.

D. Always practice First In-First Out (FIFO) to avoid creating excess waste.

E. A chemical inventory must be posted on the front of the flammable cabinet.

F. It is the responsibility of the user to ensure all HM is properly labelled, have a current SDS on file and available for each product, know and understand the contents.

* EMD has a limited amount of space to store excess HM for reissue. Contact EMD for an appointment in assisting you with large quantities of excess hazardous materials. We will not accept “truck loads” of excess HM.

Contact EMD for additional information at 502-624-3598.

POSSIBLE AREAS OF CONCERN

CHARACTERIZATION

HANDLING PROCEDURES

GENERAL INFORMATION

LEAD CONTAINING PAINT

(SURFACE PREPARATION-RENOVATION)

401 KAR 31, 32, 33 and 40 CFR 260-262

Lead paint is common in some old buildings. Increased health risks are associated with improper handling procedures.

Lead has been used in paint to enhance durability. When preparing areas for resurfacing/repainting worker safety procedures must be followed. Lead-based paint will only be removed by licensed, certified workers.

Step 1 Contact EMD at 502-624-5245 to schedule an on-site inspection or submit a Demand Maintenance Order through the DPW Demand Maintenance Order Section. See Appendix L for instructions.

Step 2 EMD will review the building survey information to verify if lead-based paint is present.

Step 3 If required, EMD will perform a lead-based paint…

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