j2_JOC_112M_HAZWASTE_PLAN.doc

ATTACHMENT J12

ATTACHMENT J2

Redstone Arsenal

Regulation 200-6

Environmental Quality

Redstone Arsenal

Hazardous Material/

Waste Management

Program: Hazardous

Material/Waste

Management Plan

Headquarters

US Army Garrison - Redstone

Redstone Arsenal, AL 35898-5000

31 August 2002

UNCLASSIFIED

Redstone Arsenal Regulation 200-6 US Army Garrison - Redstone

Redstone Arsenal, Alabama 35898

Environmental Quality:

HAZARDOUS MATERIAL/WASTE MANAGEMENT PROGRAM:

HAZARDOUS MATERIAL/WASTE MANAGEMENT PLAN

OFFICIAL:

//s//

COL, OD

Garrison Commander

History. This printing is the initial publication as a Redstone Arsenal Regulation. This information was previously provided in AMCOMR 200-2, 16 Feb 1994, which is obsolete.

Summary. This procedure establishes a Hazardous Materials/Waste Management Plan for Redstone Arsenal. It establishes policy, procedures, and responsibilities for all activities to ensure compliance with environmental laws, regulations, and Army regulations.

Applicability. This regulation applies to all primary elements of the US Army Aviation and Missile Command (USAAMCOM) on Redstone Arsenal and, by concurrence, to all tenant activities and special assigned units on Redstone Arsenal.

Proponent and exception authority. The proponent of this regulation is the Director, Directorate of Environment and Safety, US Army Garrison - Redstone. The proponent has the authority to approve exceptions to this regulation that are consistent with law or regulation.

Army management control process. This regulation does not contain management control provisions in accordance with AR 11-2.

Suggested Improvements. Users are invited to send comments and suggested improvements on DA Form 2028 (Recommended Changes to Publications and Blank Forms) to Directorate of Environment and Safety (AMSAM-RA-DES), US Army Garrison - Redstone, 4488 Martin Road, Redstone Arsenal, AL 35898.

Distribution. This publication is approved for public release; distribution is unlimited.

TABLE OF CONTENTS

PURPOSE

REFERENCES

EXPLANATION OF ABBREVIATIONS AND TERMS

POLICY

RESPONSIBILITIES

APPENDIX A - Hazardous Waste Management Instructions

APPENDIX B - Hazardous Waste Identification

APPENDIX C - Hazardous Waste Handling and Compatibility

APPENDIX D - Training Requirements and Documentation

APPENDIX E - Hazardous Waste Minimization (HAZMIN) Program

APPENDIX F - The Hazardous Waste Management Plan

APPENDIX G – Hazardous Materials and Waste Management System (HMWMS)

APPENDIX H – Polychlorinated Biphenyls Standing Operating Procedures

GLOSSARY

1. PURPOSE.

a. This regulation establishes policy, assigns responsibilities and prescribes procedures for a Hazardous Waste Management Plan in accordance with the Resource Conservation and Recovery Act (RCRA) of 1976; the Hazardous Waste Management System (40 Code of Federal Regulations (CFR), (Parts 122-124, 260-270, 300-372; and 49 CFR, Parts 172-173); the Alabama Department of Environmental Management's Hazardous Management Regulations, Division 14 and AR 200-1, paragraph 6-4b.

b. This regulation provides a single source document available for use by all personnel involved with hazardous materials and waste to ensure proper identification, packaging, storing, transporting, treatment and/or reporting of hazardous waste on Redstone Arsenal.

c. This regulation provides guidance to all personnel that are involved with hazardous wastes that are, or could potentially be, reported to federal, state, and/or local environmental agencies and/or items that may ultimately be declared wastes.

d. The regulation describes procedures for proper turn-in of hazardous waste to the Defense Reutilization and Marketing Office (DRMO) for disposal.

2. REFERENCES.

a. Hazardous Waste Management System, US Environmental Protection Agency, 40 Code of Federal Regulations, Parts 260 – 270 and 300 - 372; 49 CFR, Parts 100-185, 1 July 1996, and subsequent amendments.

b. Division 14, Hazardous Waste Management Program, Revised Effective 2 Apr 91

c. AR 200-1, Environmental Protection and Enhancement, 21 Feb 97

d. AMCOMR 742-2, 24 Apr 98, subject: Ammunition Surveillance Program

e. AMCOMR 420-7, 29 Apr 97, subject: Solid Waste Management For Recyclable Materials

f. AMCOMR 75-3, 12 Oct 95, subject: Control of Class V Hazardous Materials Incident to Transportation

g. AMCOMR 385-25, 21 Jun 99, subject: Radiation Safety: US Army Test Measurement and Diagnostic Equipment Activity Worldwide Radiation Safety Program

h. Executive Order 12856, 3 Aug 93

3. EXPLANATION OF ABBREVIATIONS AND TERMS. The explanation of abbreviations and terms used in this regulation is contained in the glossary.

4. POLICY.

a. All hazardous waste generated on Redstone Arsenal, regardless of quantity, will be managed, handled, recovered, recycled, reused, containerized, stored, treated, and disposed of in accordance with the state and federal regulations listed in paragraph 1.

b. The quantities of hazardous waste generated on Redstone Arsenal will be reduced to the maximum extent possible, as prescribed by the HAZMIN Program at Appendix E.

c. All hazardous materials that are subject to federal, state, and/or local environmental reporting and/or could ultimately be declared a hazardous waste shall be tracked by storage and usage. This data will be maintained by the utilization of the Hazardous Materials and Waste Management System (HMWMS) implemented by the Directorate of Environment and Safety (DES) as set forth by Executive Order 12856. Appendix G outlines the HMWMS Program.

d. All contracts, support agreements, leases, or any other binding agreements will address and set procedures for the management of hazardous waste generated by those contracts and agreements.

e. There will not be any acceptance of any non-DA, non-AMC, or non-AMCOM hazardous waste by any organizational element or tenant of this command, except by waiver through the procedures established by this regulation.

f. All hazardous waste will be segregated into separate containers in order to prevent mixing of unlike or potentially incompatible chemicals, enhance the potential for recycling, and lower ultimate disposal costs.

g. Disposal of radioactive material will be in accordance with the procedures established by AMCOMR 385-25, Radiation Safety: US Army Test Measurement and Diagnostic Equipment Activity Worldwide Radiation Safety Program.

h. All organizations and personnel managing, handling, storing and treating hazardous waste at Redstone Arsenal will comply with the training and documentation requirements established at Appendix D.

5. RESPONSIBILITIES.

a. The Garrison Commander (AMSAM-RA), is responsible for:

(1) Establishing and conducting hazardous waste procedures IAW AR 200-1.

(2) Maintaining routine liaison with the DRMO servicing Redstone Arsenal to maintain current information on storage and disposal of hazardous waste.

(3) Serving as chairman of the Environmental Council.

b. The Director, Directorate of Environment and Safety (AMSAM-RA-DES) is responsible for:

(1) Overall management of hazardous waste (as defined in the glossary) and central coordination of the waste management program at Redstone Arsenal.

(2) Assisting in the disposal of hazardous wastes, which fail to meet the handling criterion of DRMO and do not lend itself to recycling or reuse.

(3) Performing or coordinating surveys of hazardous material handling activities and hazardous waste generation sites. These surveys will evaluate waste management practices of generators and will be followed up with guidance or requirements for corrective action where necessary.

(4) Maintaining records and serving as the point of coordination with all federal, state, and local authorities on matters concerning material/waste management.

(5) Ensuring compliance with the laws, procedures, and regulations governing hazardous waste by the activities and tenants of Redstone Arsenal.

(6) Providing guidance to assist generators in obtaining the analysis of hazardous waste and suspected hazardous wastes.

(7) Notifying Commander, US Army MEDDAC, Preventive Medicine Service, of any hazardous waste incident involving personnel exposure.

(8) As a member of the Environmental Council, the Director will serve as advisor and point of contact on procedural and technical matters for the Environmental Council.

c. The Director, Directorate of Logistics (AMSAM-RA-L) is responsible for:

(1) Providing on-post transportation of explosive or reactive wastes.

(2) Providing storage space and/or disposal for explosive contaminated reactive waste (Class V).

(3) Serving as a Member of the Environmental Council.

d. The Alabama Institute for the Deaf and Blind (AIDB) is responsible for maintaining an adequate supply of DOT approved Performance Oriented Packaging (POP) containers that meet the UN standard as listed in 49 CFR 178.503.

e. The Chief, Defense Reutilization and Marketing Office (DRMO-VJP) is responsible for:

(1) Disposition of all hazardous waste generated at Redstone Arsenal except chemical/biological/nuclear warfare agents, radioactive wastes, waste containing explosives and propellants, and unique or unstable/reactive laboratory waste, and hazardous waste destined for off-site disposal outside of DRMOs contracting responsibilities.

(2) Storing all accepted hazardous waste in Conforming Storage Facilities, inspecting and maintaining inspection logs, and record keeping in accordance with the procedures established in the RSA Part B Hazardous Waste Storage Permit, 15 Apr 98.

(3) Properly manifesting all hazardous waste being transported to final disposal sites (except those exempted above in paragraph 5e(1)).

(4) Accepting accountability of all property identified as hazardous waste (except those exempted above in paragraph 5e(1)) approved non-leaking, safe to handle containers.

(5) Assisting the Environmental Coordinator (EC) in providing detailed guidance for proper handling and recycling of hazardous waste.

(6) Full participation in any RSA/DA hazardous waste tracking effort.

(7) Serving as a member of the Environmental Council.

f. The Chief, Legal Office (AMSAM-GC), is responsible for:

(1) Serving as legal counsel for the Environmental Council and the DES.

(2) Reviewing environmental correspondence, permits, contracts, actions, and other documents as required to ensure compliance with applicable regulations and laws.

(3) Assisting in the identification and interpretation of regulatory requirements impacting hazardous waste management.

g. The Chief, Preventive Medicine Service (MCXW-PHEC), is responsible for:

(1) Providing medical surveillance of all eligible persons with the potential for exposure to hazardous waste.

(2) Serving as a member of the Environmental Council.

h. The Chief, Safety Office (AMSAM-SF), is responsible for:

(1) Providing guidance and assistance to the EC as needed regarding employee safety during the management, treatment, storage, disposal, handling, and cleanup of hazardous waste.

(2) Managing radiological wastes and any wastes that consist of a combination of radiological and hazardous wastes (mixed wastes).

(3) Serving as a member of the Environmental Council.

i. The Chiefs of the primary organizational elements are responsible for:

(1) Complying with the provisions and procedures of this regulation.

(2) Appointing points of contact (POCs) to facilitate the management of hazardous waste within their organization and providing a written memorandum to DES identifying the POC and an alternate. Through the POCs, the Chiefs are responsible for ensuring that hazardous wastes generated by their organizations are managed in an environmentally and legally acceptable manner. This will include ensuring that:

(a) Hazardous wastes are stored and handled as indicated in Appendix A, paragraph 2b (Storage Procedures); and Appendix C, Hazardous Waste Handling and Compatibility.

(b) Hazardous wastes are not stored for more than 3 days at a satellite accumulation point, if the quantity has reached 55 gallons. Hazardous wastes shall not be stored for more than 90 days at an approved 90-day hazardous waste accumulation point.

(c) All hazardous material/hazardous waste is tracked; this includes all such items that are surveyed, acquired, discovered, or otherwise in possession of the generator. Tracking and record keeping will ensue from the time of initial possession until the time of turn-in to DRMO or other entity authorized by the EC.

(3) Ensuring that the personnel under their supervision who deal with hazardous waste are trained annually in accordance with the requirements set forth in Appendix D.

(4) Verifying the integrity and security of all waste generated in their areas of responsibility.

(5) Surveying their facilities and providing reports on hazardous waste generation, management, handling and storage as requested by the EC.

(6) Coordinating with the EC regarding all hazardous waste related matters.

(7) Providing detailed guidance through written standing operating procedures (SOPs) for the management of hazardous waste in their areas of responsibility. These SOPs will be coordinated with the DES before promulgation.

(8) Transferring hazardous wastes to the DRMO in coordination with the EC.

(9) Mitigating any spills of hazardous waste through the procedures established in the "Spill Prevention Control and Countermeasure (SPCC) Plan / Installation Spill Contingency Plan (ISCP) for Oil and Hazardous Substances."

(10) Serving as members of the Environmental Council, as requested.

j. The EC (AMSAM-RA-DES-IC) is responsible for:

(1) Overseeing the hazardous materials/waste storage and tracking operations of assigned organizations.

(2) Supporting the assigned organizations in compliance with matters relating to the management, storage, transportation, treatment, turn-in and disposal of hazardous materials/waste.

(3) Inspecting hazardous material/waste areas and providing assistance to ensure material is being managed in compliance with all federal, state and DA regulations.

APPENDIX A

HAZARDOUS WASTE MANAGEMENT INSTRUCTIONS

1. CONCEPT.

a. All hazardous waste, regardless of the quantity generated, must be controlled and managed to ensure compliance with the Hazardous Waste Management System and this regulation.

b. Each generator has the responsibility to manage, store, and dispose of hazardous waste by established procedures.

c. Chemicals may be turned in to the DRMO with prior approval by the EC. Chemicals that are approved for direct turn-in will be marked hazardous materials on the turn-in document (DD Form 1348-1A) unless designated as predetermined hazardous waste by definition in the Glossary. This waste must be packaged in proper United Nations approved Performance Oriented Packaging (POP) containers that are non-leaking, safe to handle and able to withstand normal storage and handling.

2. PROCEDURES.

a. Turn-In Procedures

(1) All hazardous waste generated at Redstone Arsenal must be collected and segregated to the greatest extent possible. Each barrel, drum, box, or container will identify the hazardous waste it contains, by listing the container contents, accumulation start date and proper waste codes. Containers may be obtained from the AIDB. The generator is responsible for obtaining all containers used for turn-in to the DRMO.

(2) All hazardous waste, except for unique laboratory waste, unstable/reactive, radioactive, chemical/biological/nuclear warfare agent waste, will be turned into the DRMO unless the EC determines this not to be in the best interest of Redstone Arsenal. All hazardous waste will be packaged in approved POP containers. The DRMO will not accept containers that are leaking, dented, rusted or bulging. Turn-in activities are to be coordinated with the EC to preclude any problems concerning proper packaging and waste containers.

(3) Hazardous Property turned in to DRMO must be described on DD Form 1348-1A unless otherwise directed by the DRMO. A completed “Hazardous Material/Hazardous Waste Profile Form” must accompany the DD Form 1348-1A. A Hazardous Waste Profile Form must be provided for each waste stream initially and must be updated yearly. The generator must coordinate with the EC to obtain a Waste Profile Number and information on proper marking and labeling.

(4) All generators must prepare documentation for turn-in to DRMO. The DD Form 1348-1A, Defense Turn In Document (DTID), must be provided for each container of hazardous waste and must reflect the following:

(a) Valid National Stock Number (NSN) and product name as catalogued in the supply system, or Local Stock Number/Federal Stock Class (LSNIFSC) and chemical name of hazardous components or federal supply classification SB 708-21.

(b) Billing Department of Defense Activity Address Code (DODAAC).

(c) Exact weight in pounds including container weight.

(d) Turn-in address to include POC and phone number.

(e) Cost center identified in the lower left corner of the DD Form 1348-1A.

(5) Hazardous Material/Hazardous Waste Profile Form.

(a) Turn-in activities are required to provide a Hazardous Material/Hazardous Waste Profile Form. The forms can be obtained from the EC. A Hazardous Material/Hazardous Waste Profile Form is required with turn-ins of (1) hazardous waste (HW), (2) used and/or opened Hazardous Material that meets the definition of a HW when discarded and, (3) discarded, out-of-date, and/or off-specification hazardous material.

(b) Generators will complete the Profile Sheet by providing requested information. The abbreviation “N/A” will be entered in blocks that are not applicable. The material composition for each component shall be identified by estimating the range (in percentages) in which the component is present. The information may be based on user's knowledge provided supporting documentation is enclosed.

(c) Chemical analysis is required if documentation is not available to support user's knowledge. Examples of documentation are descriptions of waste production processes including raw materials, end products and other intermittent sources of waste or historical/published data on the process or waste. Analysis on open containers of hazardous material/waste by a chemical lab is preferable. All analyses should be completed through the Base Operations Support Contractor Lab, located at the Water Treatment Plant in building 5428, 876-4062, unless otherwise authorized by the EC.

(d) If technical data exists (i.e., Manufacturer’s Material Safety Data Sheets (MSDSs) or generator knowledge of the contents along with supporting documentation), the requirements for turn-in are satisfied under most circumstances. Additionally, certain information is required for flammable solutions and corrosive solutions as defined by 49 CFR 172, DOT regulations. Data for flammables must include Flash Point (FP). Corrosive solutions must be accompanied by a value for corrosivity on the scale provided by 49 CFR 173.137(a)–(c). Values for FP and Boiling Point (BP), and corrosivity must be indicated on a waste profile sheet. This information is needed to properly complete DOT shipping papers. The contents of the containers must be verified by a knowledgeable person whose name will be noted on the Hazardous Material/Hazardous Waste Profile Form.

(6) Acceptance/Rejection of Documentation or Property.

(a) All generator activities will process their documentation for turn-in to the DRMO through their assigned EC.

(b) The EC will inspect containers and ensure all documentation is complete and acceptable to the DRMO and provide any additional assistance in resolving generator discrepancies concerning turn-in documentation and proper containerization.

(c) DRMO will coordinate with each generating activity to schedule turn-in. The DRMO will direct the generator to deliver waste to the DRMO yard or the Hazardous Waste Storage Facility (HWSF), as applicable.

(7) If at any time the waste is determined to have been misidentified by the generator, it will be rejected by the DRMO. The generator will be contacted and advised to pick up the property within 7 working days. A discrepancy report will be provided to the EC.

(8) DRMO will not accept controlled medical property (Federal Supply classification 6505 – Drugs, Biologicals and Official Reagents).

(9) If the DRMO does not accept waste based on some physical criteria (e.g., inadequate or leaking containers, missing labels, unidentified components, etc.), the generator shall coordinate with an EC and take all steps necessary to correct the discrepancy. If DRMO does not accept the waste because it is not part of their mission (e.g., unique lab waste, biological warfare agent waste), the generator must turn it in directly to the HWSF through the Explosive Storage and Demolition Branch (AMSAM-RA-L-AD-ES). The generator will retain accountability of the waste, including its disposal, and will coordinate with the assigned EC to ensure proper disposal.

b. Storage Procedures.

(1) While storing hazardous waste, generators must:

· Inform the proper EC of the type and approximate quantity of waste generation.

· Maintain all 90-day waste generation/storage locations in accordance with 40 CFR 262 - 265.

· Do a visible inspection of all satellite accumulation points on a regular basis.

· Maintain a record keeping system for all 90-day storage locations for waste as outlined by 40 CFR 262 and 265. This system shall track the type and quantity of waste from generation to turn-in.

· Store the waste in POP containers that are in good condition (i.e., not leaking, rusted, bulging, or dented).

· If this is not possible, place the waste in another container that is compatible with the waste.

· Store liquid or sludge-type wastes in non-leaking safe-to-handle drums ONLY.

· Keep the containers closed at all times except when it is necessary to add, sample, or remove waste.

· Mark the containers using either a label or an indelible broad stroke marker with the words "Hazardous Waste", chemical name or words identifying the origin of the waste stream, the EPA waste code number, and the accumulation start date on each container.

· Maintain aisle space sufficient to enable inspection of all containers.

(2) A generator may accumulate up to 55 gallons of hazardous waste or 1 quart of acutely hazardous waste at the site of initial generation. The accumulation start date, under these conditions, is set by the day that the last drop of waste is deposited in the container. The generator has 3 days from this date to move the waste to an approved 90-day storage facility for disposition.

(3) The DES may approve the establishment of a 90-day storage area that meets all regulatory requirements. The generator may then store waste for up to 90 days within the specified area. This accumulation period begins on the day that the last drop of waste is deposited in the container. Before the 90 days has lapsed, the generator must turn in and remove the waste for disposition. The cost for design and construction of 90-day storage facilities shall be assumed by the generating activity.

(4) Generators must collect and segregate wastes into individual containers whenever feasible. For example, if trichloroethylene is the generated waste, then all trichloroethylene generated should be placed in a single container or containers (depending upon quantity). By this method, chemical integrity is maintained and disposal or recycling is simplified. In addition, this ensures that disposal costs are kept to an absolute minimum.

(5) If the waste generated is a mixture resulting from a particular process, then that mixture's integrity must be maintained by not mixing it further with anything else.

(6) Every effort must be made to prevent any mixing of incompatible waste or materials that may cause the potential for reaction, fire, or explosion. Containers of incompatible waste must not be stored adjacent to each other. If wastes must be stored in the same general area, they will be separated by space or a physical barrier that will preclude accidental mixing in the event of a spill. A physical barrier is preferred.

(7) All records generated regarding the inspection of hazardous waste storage areas must include the following:

(a) For 90-day storage:

· Reflect container(s) condition – If container(s) are open, if any rusting, cracks, bulges or leaks present.

· Record container(s) markings – Proper accumulation start date, proper labeling and proper container content markings.

· Record the storage structure condition - Any structural deterioration, is adequate aisle space present between containers, and any corrective action taken for repairs.

· Record if the facility phone is functioning.

· List all spill control features located in storage facility – are empty drums/overpacks available, unused absorbent material available, personal protective equipment available (i.e., gloves, boots, clothing, respirators, and eye protection).

· Record function status of facility emergency eyewash/shower.

· Record container(s) removal date and receiving waste facility.

(b) For Part B storage:

· Record date container(s) received, generator name and contact number.

· Reflect container(s) condition – If container(s) are open if any rusting, cracks, bulges, or leaks present.

· Record container(s) markings – Proper accumulation start date, proper labeling and proper container content markings.

· Record the storage structure condition - Any structural deterioration, is adequate aisle space present between containers, and any corrective action taken for repairs.

· Record if the facility phone is functioning.

· List all spill control features located in storage facility – are empty drums/overpacks available, unused absorbent material available, personal protective equipment available (i.e., gloves, boots, clothing, respirators, and eye protection).

· Record function status of facility emergency eyewash/shower.

· Record container(s) removal date and receiving waste facility.

(8) The generator may be required to transport the waste to the HWSF depending on his transportation capability. If the generator has no capability, the generator must arrange with Logistics Division Contractor Services for the transportation of the waste to the HWSF.

(9) At the HWSFs operated by the DRMO, DRMO will retain accountability of the hazardous waste. DRMO is responsible for the proper storage and removal of the hazardous waste from Redstone Arsenal. DRMO has the responsibility for inspecting the integrity and security of the hazardous waste while it is retained in the DRMO HWSFs. Proper maintenance of the HWSF is also the responsibility of the DRMO. The DES will render support in regard to DRMOs management of hazardous waste by executing all necessary work orders (i.e., Individual Work orders, IJOs).

c. Treatment and Disposal Procedures.

(1) DRMO must follow EPA approved methods while disposing of any hazardous waste.

(2) Certain wastes are approved at this time for thermal treatment at Redstone Arsenal's demolition area. These wastes are propellant, explosive and pyrophoric related or are liquids contaminated with these waste. These wastes are considered as unusually unstable and dangerous and require special handling. This hazardous waste must be coordinated for treatment with the Explosive Storage and Demolition Branch (AMSAM-RA-L-AD-ES), building 8700. Prior arrangements must be coordinated with Explosive Storage and Demolition Branch (ESDB) before delivery.

(3) If wastes are unsuitable for disposal by the methods described in (1) and (2) above, the generator shall contact the DES/EC to make arrangements for proper disposal.

(4) All records pertaining to hazardous waste disposal must be kept for 3 years after the closing of the facility maintaining such records.

3. MANIFESTING AND RECORDKEEPING.

a. The generation of hazardous waste will be documented as to location and date of generation, identity, quantity, characteristics, and disposition (i.e., turned in to DRMO or open burned).

b. Whenever hazardous waste is moved, turned in, stored, or disposed of by DRMO or ESDB, a DD Form 1348-1A and a Hazardous Material/Hazardous Waste Profile Form must be completed. The generator, DRMO, and ESDB will retain copies of the above on file in accordance with paragraph 2c(4) above. Additionally, DA Form 581 will be required for the turn-in of munitions to ESDB.

4. INSPECTIONS.

a. The DRMO shall ensure weekly inspections are conducted at the Hazardous Waste Storage Facilities under DRMO control. The DES shall ensure weekly inspections are conducted at the Hazardous Waste Storage Facilities under DES control. All inspections will be documented on an approved inspection log.

b. Individual generators shall develop a plan for inspections on a weekly basis and appoint inspectors to inspect and report on conditions within their areas of responsibility as outlined by 40 CFR 262 and 265. All storage sites at the generator locations must be inspected weekly.

c. The Fire Department shall notify the DES immediately of any incident or condition involving hazardous materials or hazardous waste (i.e., leakage, spill, improper handling or storage) observed during fire prevention or pre-fire planning inspections.

d. The Safety Office (AMCOM-SF) is required to inspect all buildings on Redstone Arsenal IAW AR 385-10, Chapter 4 and AMCOM Supplement 1 to AR 385-10. The Safety Office will notify the DES of locations identified on safety inspections where hazardous material and hazardous waste are improperly stored.

e. The DES shall perform ECAS inspections annually. Any discrepancy discovered shall be corrected by the offender within 14 working days unless otherwise specified by the DES/EC. Inspections will be documented and copies of reports of inspections provided to the inspected facilities and activities upon request.

f. Representatives of the DES will conduct random inspections of storage, treatment, and generator activities to ensure compliance with federal and state requirements and the provisions of this regulation. The purpose of these inspections will be to ensure proper waste identification, storage practices (including labeling and marking, container integrity and security), and record keeping. Generators will document discrepancies discovered during inspections and take corrective actions immediately. The generator will also document corrective action and notify the DES in appropriate cases (i.e., hazardous waste spill, misidentified turn-in, etc.).

5. WAIVERS.

a. There will be no storage, treatment, or disposal of non-DOD, non-DA, non-AMC, or non-AMCOM hazardous waste at Redstone Arsenal by any activity without approval by the Garrison Commander.

b. All waiver requests must be submitted to, reviewed, and recommended by the DES for forwarding to higher authority.

c. Once a waiver is approved, storage, treatment, or disposal actions may proceed with coordination with proper activities.

d. The only exception to obtaining a waiver for acceptance of any non-AMCOM waste is when an imminent danger exists to the public if the waste is not taken. In such an event, a waiver from higher headquarters is not required. However, coordination with and approval from the DES is required prior to any acceptance of such waste.

6. PERSONNEL TRAINING.

a. Facility personnel involved in the management, handling, storage, disposal, and transportation of hazardous waste must comply with training requirements as set forth in 40 CFR, Part 264.16. This training is designed to inform personnel of the hazards of handling hazardous waste, the use of emergency and monitoring equipment, and the provisions of the various laws and regulations as provided in this and other regulations as described in Appendix D.

b. The training may be formal classroom or on-the-job training as supervisors deem necessary. However, on-the-job training must be instructed by a responsible individual that has received formal training. Such training shall be documented by DD Form 1556 that has been submitted to the Personnel and Training Directorate (AMSAM-PT-CP-TC).

c. All personnel involved in the management, handling, storage, disposal, or transportation of hazardous waste must be trained or instructed within 6 months of start of hazardous material/waste work assignment. Employees must not work unsupervised with hazardous waste until they have been trained or instructed in the proper procedures and precautions of handling such waste.

d. Every employee involved in handling hazardous waste must attend an annual review of this initial training. This review training must be documented in the employee's training record in accordance with 40 CFR, Part 264.16.

e. Supervisors of employees handling, storing, disposing, or transporting hazardous waste must maintain the following:

(1) A written job description, job title, and employee’s name for each position that is involved with hazardous waste. These items must be kept by the employee’s supervisor and be made available for review by authorized personnel.

(2) A written description of the type and amount of both introductory and continuing training that will be or has been given to each employee.

f. Training records on current personnel must be kept until closure of the activity or facility. Training records on former employees must be kept for 3 years from the date the employee last worked at the activity or facility.

7. ENVIRONMENTAL COUNCIL.

a. The Redstone Environmental Council will serve as the Environmental Quality Control Committee (EQCC) as required in AR 200-1, paragraph 15-11.

b. As required by AR 200-1, the Environmental Council is established to serve as a forum for discussions of environmental problems and initiatives to include hazardous waste/ materials management problems and issues. The Environmental Council is informal and chaired by the Installation Commander or his designated representative.

c. The Environmental Council will convene monthly or as deemed necessary.

d. The Environmental Council advises the Installation Commander on environmental priorities, policies, strategies, and programs. The purposes of the Environmental Council include but is not be limited to:

(1) Resolving and coordinating all recycling efforts and disposal program issues and plans.

(2) Considering and optimizing recycling operations to minimize the generation of hazardous waste.

(3) Assisting the DES of each site in implementing the Hazardous Waste Management Plan (Appendix F).

(4) Assisting in the resolution of program conflicts.

(5) Coordinating alternate storage and disposal plans.

(6) Planning and coordinating the minimization of hazardous waste generations to meet the HAZMIN goals as stated in the HAZMIN Plan.

e. The membership of the Environmental Council is listed in a charter in the Environmental Office.

f. In addition to the membership identified in the charter, individual generators of hazardous waste are required to attend as regular members. The generators will be determined and appointed by the chairman of the Environmental Council.

8. HAZARDOUS WASTE STORAGE AND DISPOSAL ACTIVITIES.

a. Hazardous Waste Storage Facility (HWSF) - Buildings 8621-8625 and 8630-8633, phone 876-6401.

b. Explosive Demolition Area (EDA) - Building 8404 and 8700, phone 876-1332.

c. DRMO - Building 7408, phone 842-2532.

9. HAZARDOUS WASTE POINTS OF CONTACT AT REDSTONE ARSENAL.

a. Directorate of Environment and Safety (AMSAM-RA-DES-IC), 876-6122.

b. Explosive Storage and Demolition Branch (AMSAM-RA-L-SU-ES), Logistics Services Division, 876-1332.

c. DRMO, 842-2532.

d. RSA Environmental Laboratory, 876-4062.

e. Installation On-Scene Spill Coordinator, DES, 876-6122.

f. Environmental Coordinator, Ms. Linda W. Smith, 876-6492.

g. To report a spill, contact the Fire Department Emergency at 911, then state your location as being on Redstone Arsenal.

APPENDIX B

HAZARDOUS WASTE IDENTIFICATION

1. CONCEPT.

a. Generators, managers, treaters, storers, and/or disposers of spent material and process waste are to use this list as guidance in determining whether or not the spent material or process waste can be considered a hazardous waste.

b. If a spent material or process waste is a solid waste and is not listed in 40 CFR, Part 261 Appendix VII or Appendix VIII, the criteria characteristics described therein will be used to determine whether waste is hazardous or not. If the generator, manager, treater, storer, or disposer is in doubt of whether a spent material or process waste is hazardous or not, the waste must be considered hazardous and handled as hazardous waste until determined otherwise by an EC.

2. CRITERIA.

a. Criteria for identifying characteristics and listed hazardous waste.

(1) When making a determination as to whether a waste is a hazardous waste, one must first determine if the waste meets the definition of a solid waste. The definition of a solid waste is: Any solid, liquid, or gas that is not specifically excluded by 40 CFR, Part 261 Appendix VII or Appendix VIII. It may include any garbage, refuse, sludge, or any other industrial, maintenance, or laboratory waste intended for discard.

b. Criteria for identifying a hazardous waste.

(1) A solid waste (as defined above) may be a hazardous waste if it exhibits a characteristic or characteristics that:

· Causes or significantly contributes to an increase in mortality or serious irreversible or incapacitating reversible illness.

· Poses a substantial present or potential hazard to human health or the environment while being treated, stored, transported, disposed of or otherwise managed.

· Exhibits hazardous characteristics as determined by: Material Safety Data Sheets (MSDS), by laboratory analysis, and/or by documented user knowledge.

(2) Additionally, it may be classed as a hazardous waste if:

· It has been found fatal to humans in low doses.

· It contains any of the toxic characteristics as detailed in 40 CFR, Part 261, Subpart C and exceeds the regulatory limits listed therein.

· It is a listed waste detailed in 40 CFR, Part 261, Subpart D. Details regarding a listed hazardous waste can be found in Section III below.

(3) Hazardous waste falls under two broad categories; these are characteristic wastes and listed wastes. The details of these are discussed below in Sections II and III, respectively.

3. CHARACTERISTIC HAZARDOUS WASTE

a. Characteristic wastes are determined by criteria set for four parameters - ignitability, corrosivity, reactivity, and toxicity; these are described in more detail below.

b. These characteristics can be:

(1) Measured by available standardized test methods which are designated in 40 CFR; or

(2) Reasonably detected by the generators of hazardous waste through their knowledge of the waste.

c. Hazardous waste is assigned an EPA Hazardous Waste Number as shown in 40 CFR, Part 261, Subpart C. These are based on the four characteristics mentioned above.

4. CHARACTERISTICS OF IGNITABILITY.

a. Waste exhibits ignitability if it:

(1) Is a liquid, other than a solution containing less than 24 percent alcohol by volume, and has a flashpoint less than 60 C (140 F) as determined by Pensky-Martens Closed Cup Tester, using the test method specified in ASTM Standard D-93-79 or D-93-80, or Setaflash Closed Cup Tester, using the test method specified in ASTM Standard D-3278-78, or an equivalent test method approved under procedures set forth in 40 CFR, Parts 260.20 and 260.21.

(2) Is not a liquid and is capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard.

(3) Is an ignitable compressed gas as defined in 49 CFR, Part 173.300.

(4) Is an oxidizer as defined in 49 CFR, Part 173.127.

b. Waste that exhibits the characteristics of ignitability has the EPA Hazardous Waste Number of D001.

5. CHARACTERISTICS OF CORROSIVITY.

a. Waste exhibits corrosivity if it:

(1) Is aqueous and has a pH less than or equal to 2.0 or greater than or equal to 12.5 as determined by a pH meter using Method 9040 in “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods”, EPA publication SW-846.

(2) Is a liquid and corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.25 inch) per year at a temperature of 55 degree Celsius (130 F) as determined by method TM-01-69 in EPA publication SW-846.

b. Waste that exhibits the characteristics of corrosivity has the EPA Hazardous Waste Number of D002.

6. CHARACTERISTICS OF REACTIVITY.

a. Waste exhibits reactivity if it has any of the following properties:

(1) Is normally unstable and readily undergoes violent change without detonation.

(2) Reacts violently with water.

(3) Forms potentially explosive mixtures with water.

(4) When mixed with water, it generates toxic gases, vapors, or fumes, in sufficient quantities to present a hazard to health or the environment.

(5) It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate toxic gases, vapors or fumes in sufficient quantities to present a hazard to health or the environment.

(6) Is capable of detonation or explosive reaction if subjected to a strong initiating source or if heated under confinement.

(7) Is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.

(8) Is a forbidden explosive as defined in 49 CFR, Part 173.51 or a Class A explosive as defined in 49 CFR, Part 173.53 or a Class B explosive as defined in 49 CFR, Part 173.88.

b. Waste that exhibits the characteristics of reactivity has the EPA Hazardous Waste Number D003.

7. TOXICITY CHARACTERISTIC.

a. A solid waste exhibits the characteristic of toxicity if, using the test methods described in 40 CFR, Part 261.24, a representative sample of the waste contains any of the contaminants listed in table 1 of 40 CFR, Part 261.24 at the concentration equal to or greater than the value indicated in table 1 at the concentration equal to or greater than the respective value given in that table.

b. The corresponding EPA Hazardous Waste Number is also identified in table 1.

8. LISTED HAZARDOUS WASTE

a. Listed hazardous wastes are indicated in 40 CFR, Part 261, Subpart D.

b. These consist of four waste categories and are coded as F, K, U, and P followed by a three-digit numeral (i.e., F003). The F codes identify non-specific source wastes (i.e., certain mixed wastes). The K codes apply to certain specific sources (i.e., waste water treatment sludges, industrial operation wastes). The U and P coded wastes are specific waste chemical products that are toxic or acutely toxic respectively.

c. The specific waste, including its corresponding EPA Hazardous Waste Code number is listed in 40 CFR, Part 261, Subpart D.

APPENDIX C

HAZARDOUS WASTE HANDLING AND COMPATIBILITY

1. CONCEPT.

a. Hazardous wastes and hazardous materials have the potential for violent reaction, fire, generation of poison gases, and explosion if mixed with other chemicals or compounds not compatible with them.

b. All efforts must be made to keep incompatible waste and materials from coming in contact with one another to avoid the above results.

c. The mixing of waste and materials, in addition to causing potential risks, increases the burden on the generators for analysis and identification of the waste at such time as they are turned in to the DRMO for disposal. By maintaining proper segregation and identification, the procedure for turn in and disposal is simplified.

2. PROCEDURES.

a. Storage and Handling.

(1) Generators will abide by all requirements set forth in Appendix A, paragraph 2b Storage Procedures.

(2) Generators must collect and segregate wastes into individual containers whenever feasible. For example, if trichloroethylene is the generated waste, then all trichloroethylene generated should be placed in a single container or containers depending upon quantity. By this method, chemical integrity is maintained and disposal or recycling is simplified.

(3) If waste generated is a mixture resulting from a particular process, then that mixture's integrity must be maintained by not mixing it with anything else.

(4) Every effort must be made to prevent any mixing of incompatible waste or materials, which might cause the potential for reaction, fire, or explosion. Containers of incompatible waste must not be stored adjacent to each other and if stored in the same general area will preferably have a physical barrier precluding accidental mixing in the event of a spill.

(5) The list in paragraph 2b below is provided as a general guide for preventing mixing of incompatible waste. Although this list is provided for general guidance on storage and disposal, each action or chemical must be investigated individually to ensure compatibility.

b. Compatibility List.

The following list should be used as a general guide only for separation of waste types. The list is broken down into broad groups (1, 2, 3, etc.) and subgroups (A and B). No chemical type from a group should be mixed with another group or subgroup. This rule applies to the accumulation of differing waste products and the storage of those products. The consequences indicated are general in nature but provide information as to the risks of integration of chemicals from one group with another group. This list was extracted from 40 CFR, Part 265, Appendix V.

GROUP 1

A

B

Acetylene sludge

Acid Sludge

Alkaline caustic liquids

Acid and water

Alkaline cleaner

Battery acid

Alkaline corrosive liquids

Chemical cleaners

Alkaline corrosive battery fluid

Electrolyte, acid

Caustic wastewater

Etching acid

Lime sludge and other corrosive alkalis Pickling liquid and other corrosive acids

Lime Wastewater

Spent acid

Lime and water

Spent mixed acid

Spent Caustic

Spend sulfuric acid

Potential Consequences: Heat generation; violent reaction.

GROUP 2

Aluminum

Any waste in Group

Beryllium

1-A or 1-B

Calcium

Lithium

Magnesium

Potassium

Sodium

Zinc Powder

Other reactive metals and metal hydrides

Potential Consequences: Fire or explosion; generation of flammable hydrogen.

GROUP 3

Alcohols

Any concentrated waste

Water in Groups 1-A or 1-B

Calcium

Lithium

Metal hydrides

Potassium

S02 C12 SOC13 PC13

CH3SiCl3 and other water-reactive waste

Potential Consequences: Fire, explosion or heat generation; generation of flammable or toxic gases.

GROUP 4

Alcohols

Concentrated

Aldehydes

Group 1-A or 1-B wastes

Halogenated hydrocarbons

Group 2 - A wastes

Nitrated hydrocarbons

Unsaturated hydrocarbons

Other reactive organic compounds and solvents

Potential Consequences: Fire, explosion or violent reaction.

GROUP 5

Spent cyanide and sulfide solutions

Group 1-B wastes

Potential Consequences: Generation of toxic hydrogen cyanide or hydrogen sulfide gas.

GROUP 6

Chlorates

Acetic acid

Chlorine and other organic acids

Chlorites

Concentrated mineral acids

Chromic acid

Group 2-A wastes

Hypochlorites

Group 4-A wastes

Nitrates

Other flammable wastes

Nitric acid, fuming and combustible wastes

Perchlorates

Permanganates

Peroxides and other strong oxidizers

Potential Consequences: Fire, explosion, or violent reaction.

APPENDIX D

TRAINING REQUIREMENTS AND DOCUMENTATION

1. CONCEPT.

a. All Redstone Arsenal personnel supervising, handling, storing, or disposing of hazardous waste must receive annual training that instructs them regarding the performance of their duties in a manner to achieve regulatory compliance.

b. A supervisor or instructor who has received formal classroom training may administer on-site/on-job training but only with advance approval of the Directorate of Environment and Safety and the Civilian Personnel Office. Such training must be formally documented.

c. All documentation of training must meet the criteria and requirements of paragraph 2(e) below and be maintained on file for at least 3 years at the employee's work location. All records must be made easily accessible and available to state/federal regulatory agencies or the EC on request.

2. PERSONNEL TRAINING.

a. The following requirements are paraphrased from the Alabama Department of Environmental Management Regulations, Division 14 Hazardous Waste Program Regulation:

(1) Personnel Training - Facility personnel must successfully complete a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility's compliance with the requirements of this Section. The owner or operator must ensure that this program is documented as required under paragraph 2(e).

(a) This program must be directed by a person trained in hazardous waste management procedures and must include instruction which teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the position in which they are employed.

(b) The training program must be designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including where applicable:

· Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment;

· Key parameters for automatic waste feed cut-off systems;

· Communications or alarm systems;

· Response to fires or explosions;

· Response to ground water contamination incidents; and

· Shutdown of operations.

(c) Facility personnel must successfully complete the program required within 6 months after the date of their employment or assignment to a facility, or to a new position at a facility. Employees hired must not work in unsupervised positions until they have completed the training requirements of this Section.

(d) Facility personnel must take part in an annual review within 365 days after beginning initial training.

(e) Supervisors must maintain the following documents and records at the facility on each employee assigned to, working with or trained in Hazardous Waste Handling:

· The job title for each position at the facility related to hazardous waste management and the name of the employee filling each job.

· A written job description for each position listed under paragraph 2e(1) of this Appendix. This description may be consistent in its degree of specificity with descriptions for other similar positions in the same company location or bargaining unit, but must include the requisite skill, education, any…