Chap 2 - Haz Mat Waste - Jan 2008.pdf

Chapter 2: Hazardous Materials and Waste Management Procedure

1. Purpose This document addresses the management of hazardous materials and waste at Fort Greely (FGA). This Procedure defines appropriate practices for dispensing hazardous materials, as well as, collecting any resulting waste in a safe and controlled manner in accordance with applicable US Army, installation, state and federal requirements.

This procedure addresses: dispensing of hazardous materials; placement and design of dispensing, storage and waste collection areas; waste handling; inspections; training; and reporting requirements. The procedure addresses three types of waste: Hazardous Waste as defined in 40 CFR 261, Universal Wastes as defined in 40 CFR 273 and Regulated Non- Hazardous Waste (oils, coolants, etc.) excluding municipal solid waste and inert debris.

2. Definitions

Hazardous Materials: A list of chemicals and materials developed by DOT based on potential fire, explosion and health hazards encountered during transportation and includes all chemicals required by OSHA to have a Material Safety Data Sheet. Hazardous materials include the following categories: flammable and combustible material, toxic material, corrosive material, oxidizers, aerosols, and compressed gases.

Hazardous Material Storage Areas: Approved locations at FGA for the storage of hazardous materials.

Hazardous Waste: Waste which because of its quantity, concentration, or physical, chemical, or infectious characteristics may pose a substantial hazard to human health or the environment when improperly treated, stored or disposed of, or otherwise mismanaged. A waste is classified as a hazardous if it exhibits a hazardous characteristic (ignitability, reactivity, corrosivity or toxity) or is listed as a hazardous waste by the USEPA.

Material Safety Data Sheets: Information provided by hazardous material's manufacturer for users to understand and deal with the potential hazards associated with the material.

Satellite Accumulation Area (SAA): Established sites at FGA for the accumulation of hazardous wastes, except municipal solid waste, inert debris, medical waste, and asbestos, in containers near the point of generation, which are under the control of the operator of the process generating the waste. There shall be a clear distinction (i.e. tape, signage, separate storage lockers) between Hazardous Materials Storage Area (HMSA) and SAAs.

Universal Wastes: Consists of common materials such as fluorescent light bulbs, batteries, and mercury-containing devices, which when discarded require specific management and disposal due to the hazardous chemicals contained in them.

Regulated Non-Hazardous Waste: Materials which by definition are not a hazardous waste but when discarded require specific management and disposal (i.e. absorbent pads, oily rags, used oil and used antifreeze).

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3. Responsibilities

a. Garrison Commander The Garrison Commander is the responsible official for environmental compliance at FGA and provides overall policy and guidance associated with environmental compliance. The Commander will consult regularly with FGA Environmental (FGAENV) to insure that the installation’s environmental policies and procedures are consistent with federal, state and Army requirement and are properly implemented. The Commander will consult regularly with all installation tenant organizations and departments and facilitate resolution of conflicts regarding environmental matters that cannot be resolved at lower levels. As the Garrison Commander’s environmental representative, the FGAENV will be the point of contact for interface with Federal, State, and local environmental regulatory agencies on all environmental compliance matters associated with Garrison and tenant activities.

b. Installation Management Command (IMCOM) – Pacific IMCOM - Pacific oversees environmental management and compliance activities at FGA and provides resources for environmental program implementation. IMCOM ensures FGA’s environmental program conforms to DoD and Army requirements and provides policy and programmatic guidance to FGAENV.

c. Missile Defense Agency (MDA) – Ground-based Midcourse Defense (GMD) GMD manages all operations and activities at the Missile Defense Complex (MDC). The Site Manager will insure that all contractors and personnel providing services or conducting operations at the MDC comply with this procedure and related Federal and State environmental requirements. The Site Manager will promptly consult with FGAENV and/or the Garrison Commander, regarding any special considerations (e.g., security) or other issues that may affect environmental compliance at the MDC.

d. FGA Department of Public Works (DPW) The DPW Director manages all DPW activities and oversees the base operations and hazardous waste management contractors. The DPW will ensure that DPW activities are consistent with this procedure.

e. FGA Environmental Coordinator (FGAENV)

(1) Primary Point of Contact (POC) for environmental compliance.

(2) Submits waste exception reports to the US EPA as required.

(3) Prepares and submits EPCRA Tier II Report to the Fire Department, Local

Emergency Planning Committee, and Alaska Department of Environmental Conservation (ADEC). The report is due annually by March 1.

(4) Reports spills and submits release reports in accordance with the Spill Response and Notification Procedures provided in Chapter 5 of the FGA Environmental Procedures.

(5) Monitors FGA Small Quantity Generator (SQG) status. Implements waste minimization efforts to maintain SQG status if FGA approaches limits.

(6) If FGA exceeds the SQG limits, FGAENV will ensure necessary changes are made to operate as a Large Quantity Generator. Changes may include:

(a) Accumulation time limit reduction from 180 days to 90 days;

(b) Reduction in exception reporting from 60 days to 45 days;

(c) Submission of Biennial waste report;

(d) Preparation of a RCRA compliant contingency plan;

(e) Hazardous waste training changes

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(7) Advises the FGA Commander and all Directors, tenants, and contractors of environmental requirements and provide assistance in achieving compliance.

(8) Specifies and coordinates training to meet the requirements of this procedure.

(9) Routinely inspects hazardous material storage and dispensing areas and waste collection areas to include the Temporary Hazardous Waste Accumulation Facility for compliance with this procedure.

(10) Collaborate with hazardous materials users and waste generators on the placement of Hazardous Material Storage Areas and Satellite Accumulation Areas (SAAs) and approve the location of such facilities.

(11) May establish an area where surplus and off-spec hazardous materials may be dropped off for reuse by other departments, tenants, or contractors at no additional cost to the user. FGAENV will establish the rules for the acceptance and dispensing of surplus and off-spec materials.

(12) In the event of non-compliant activities, FGAENV will seek resolution.

(13) Provide hazardous material dispensing/storage area and SAA management training to Hazardous Waste/Materials Managers.

f. Hazardous Waste Management Contractor (HWMC) The HWMC is responsible for managing the collection, transportation, and temporary accumulation of Universal, Hazardous and regulated Non-Hazardous Waste, except municipal solid waste, inert debris, medical waste, and asbestos, according to the requirements of this procedure. The HWMC will work closely under the direction of the FGA-ENV to ensure compliance with this procedure. The HWMC will:

(1) Submit a monthly summary report by the 10th of each month for all regulated waste collected and/or shipped from FGA during the prior month. The summary will include waste type, activity date, quantity, generator, disposal facility monthly and current annual total net weight of each waste stream, and totals of hazardous and non-hazardous waste generated.

(2) Notify FGAENV if : (a) hazardous waste generated on site in a calendar month exceeds 75% (1650 lbs).of SQG limits (2205 lbs); (b) the hazardous waste accumulated on site exceeds 75% (9922 lbs) of the SQG limit of 13230 lbs; or (c) if any hazardous waste as been on-site for more than 150 days.

(3) Provide waste containers and labels for SAAs; pick up waste from SAAs and transport to FGA’s hazardous waste storage facility, and, as necessary perform waste type determinations.

(4) Operate and manage FGA’s Temporary Hazardous Waste Accumulation Facility (THWAF) consistent with this procedure and applicable Army, state and federal regulations.

(5) Perform weekly walk thru inspections and quarterly inspections of all SAAs and provide timely inspection reports to FGAENV.

(6) Assist with the preparation of manifest and exception reports.

(7) Arrange for the shipment of hazardous waste and non-hazardous regulated wastes from FGA.

(8) Perform other waste management activities as directed by FGAENV.

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g. FGA Directorates, Departments, Tenants and Contractors will:

(1) Properly manage hazardous materials and wastes in accordance with this procedure.

(2) Notify FGAENV prior to establishing a hazardous material storage/dispensing area or an SAA.

(3) Designate, in writing, to FGAENV a Primary and Secondary Alternate

Hazardous Waste/Materials Manager for each hazardous material dispensing/storage area and for each SAA.

(4) Notify FGAENV of any changes in Primary and Secondary Hazardous Waste/Material Manager assignments.

(5) Maintain copies of Material Safety Data Sheets (MSDS) for all hazardous materials being dispensed or stored at the dispensing/storage area or a location close to the area. Make the MSDS readily accessible to affected area personnel.

(6) Maintain copies of waste profiles or other generator knowledge to be used in waste characterization. Provide information to FGAENV as requested.

(7) Maintain an inventory of hazardous materials on site. Submit an updated inventory to FGAENV semi-annually. Inventories are due in the FGAENV Office by June 20th and December 20th of each year.

(Attachment 1)

(8) Notify FGAENV of the wastes being generated, especially when hazardous material usage or waste generation characteristics changes.

(9) Ensure all employees that use hazardous materials receive HAZCOM training.

(10) Ensure all employees that generate hazardous waste attend waste management training commensurate with their duties and responsibilities.

4. Operations

a. General Requirements for Hazardous Material Storage and Dispensing This section applies to hazardous materials storage and dispensing. Each department, tenant, and contractor is responsible for following the operational requirements of this section.

(1) A dispensing/storage area includes all hazardous material cabinets, drum dispensing, or areas designed to dispense or store hazardous materials and meeting the following volume requirements:

(a) Areas that contain less than five gallons (or 40 pounds) of office or cleaning chemicals will not be considered a hazardous materials dispensing/storage area.

(b) Areas containing more than 5 gallons (or 40 pounds), but less than 55 gallons (or 400 pounds) of any hazardous material will be considered a hazardous material dispensing/storage area only if so designated by FGAENV.

(c) Areas containing more than a total of 55 gallons (or 400 pounds) of any hazardous material or any amount of an extremely hazardous substance, as defined in 40 CFR 355 (Appendix A or B), or any amount of an acutely toxic chemical, as defined in 40 CFR 261.33(e), will be considered a hazardous material dispensing/storage area.

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(2) FGAENV will approve storage locations and specify labeling and signage requirements for hazardous material dispensing/storage areas. FGAENV will coordinate with the Fort Greely Fire Department for quantity limitations, fire extinguisher positioning, eye wash/shower station placement, bonding and grounding, communications, floor plans, evacuation routes and other requirements.

(3) Dispensing/Storage Area Facility and Operation Standards

(a) Signage must include, but is not limited to, emergency contact phone numbers, spill response procedures, warnings appropriate to the materials being stored and restrictions for entry.

(b) Adequate ventilation must be provided for all areas that store or dispense flammable or combustible materials.

(c) Stock shall be managed on a first in first out (FI/FO) rotation and levels should not exceed reasonable operational needs. New products shall be segregated from in-use containers.

(d) Flammable liquids shall not be dispensed into containers unless the nozzle and container are bonded properly.

(e) Secondary containment must be provided for all containers ≥ 55 gallons from which liquid hazardous materials are dispensed/stored. Impervious flooring with curbing, storage cabinets, spill-pallets, and over-pack containers are examples of suitable secondary containment. Flammable lockers not capable of containing 110% volume but that are located inside a building with impervious flooring, curbing and no drain in the near vicinity will evaluated on a case by case basis.

(f) Incompatible materials shall be segregated in such a way that spilled material from one container may not contact the drip pan or surface of the incompatible material. Incompatible materials include flammables with corrosives or oxidizers, poisons with corrosives, and caustics with acids.

(g) When a ballast or electrical equipment containing dielectric fluid is removed from service it is assumed to contain PCBs unless it is has manufacturer’s label indicating “No PCBs”.

(h) An Out of Service date must be clearly marked on any PCB containing item or equipment when it is removed from service.

(i) The facility manager will ensure that a legible PCB label is on all electrical equipment that contains greater than 50 ppm PCBs. The manager will ensure that the entrance to all rooms that have PBC electrical equipment has a PCB label.

(j) The preferred method of dispensing is by pumps from vertical drums. Facility managers shall provide drip pans for materials dispensed from horizontally placed drums. Facility managers shall inspect drip pans daily and empty contents into appropriate waste containers when free liquids, including rainwater, are detected in the pans.

(k) Damaged, leaking, surplus, expired or off-spec hazardous materials that cannot be used in a timely fashion shall be managed as Hazardous, Universal or Non-Hazardous Waste in accordance

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(l) Departments, tenants, and contractors shall advise FGAENV when they have surplus, expired or off-spec materials.

(m) Area Hazardous Waste/Materials Managers will perform weekly inspections of hazardous materials dispensing/storage areas and document their inspections. (Attachment 2)

(n) Reactive, corrosive, and flammable chemicals shall not be at stored in areas with unrestricted access.

(o) Ensure a fire extinguisher is readily accessible where flammable materials and waste are stored and that it is fully charged and monthly inspection tag completed.

(4) Container Standards

(a) All original containers of hazardous materials shall have the manufacturers’ labeling clearly visible and new product seals shall be left in place until the product is needed.

(b) Hazardous materials transferred from one container to another container must be marked in accordance with OSHA requirements (29CFR1910.112) with the manufacturer’s name, product name, hazard identifiers (flammable, corrosive, etc.,) and the appropriate hazard warnings.

(c) Empty containers previously containing hazardous materials ≥ 5 gallons must be marked “EMPTY”.

(d) Facility managers shall keep the tops and sides of containers clean and closed (more than finger tight) when not in use.

(5) Spill Prevention and Response

(a) Facility personnel shall immediately respond to spills and provide notification in accordance with the Spill Response and Notification Procedures provided in Chapter 5 of the FGA Environmental Procedures.

(b) Facility managers shall maintain and store an adequate quantity of spill response supplies (pads, booms, absorbent, salvage drum, etc.) to contain the worst-case spill scenario at or near the dispensing site.

(c) Facility managers shall immediately replace damaged, dented or rusty containers that leak or may leak because of their condition.

Promptly replace leaky spigots.

(d) Facility managers shall ensure all appropriate personal protective equipment (i.e. gloves, boots, aprons, goggles, respirators) are stored nearby.

(e) Facility managers shall ensure all drains to sewage system are identified and have spill plugs/booms available in the event of a hazardous material spill.

b. General Requirements for Waste Management This section applies to the accumulation and on-site movement of universal, hazardous and non-hazardous waste, except municipal solid waste, inert debris, medical waste, and asbestos. Each department, tenant, contractor and HWMC is responsible for following the operational requirements of this section.

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(1) An SAA includes all waste storage cabinets, drums, containers, vessels or areas set up to store limited amounts of hazardous, non-hazardous and universal waste. Any area that stores hazardous waste, in any quantity, is considered an SAA under this procedure. Determinations are made based on the following criteria. Waste storage areas must be differentiated from other shop activities.

(a) Areas that contain less than five gallons (or 40 pounds) of non-hazardous or universal waste will not be considered an SAA unless so designated by FGA-ENV.

(b) Areas storing greater than 5 gallons (or 40 pounds), but less than

55 gallons (or 400 pounds) of non-hazardous or universal waste will be considered an SAA unless otherwise designated by FGA-

ENV.

(c) All areas containing hazardous waste and any areas containing greater than 55 gallons (or 400 pounds) of any type waste will be considered an SAA.

(2) The generator will notify the FGA-ENV prior to establishing a new SAA or closing an existing SAA. FGA-ENV must approve all SAA locations and specify labeling and signage requirements. FGAENV will coordinate with the Fort Greely Fire Department for quantity limitations, fire extinguisher positioning, eye wash shower locations, grounding/bonding, communications floor plans evacuation routes and other requirements.

(3) SAA Facility and Operation Standards

(a) SAAs must be located near the work area and under the control of the operator who is generating the waste.

(b) Facility managers shall notify FGA-ENV prior to establishing a new SAA or closing an existing SAA. FGA-ENV will approve siting location and specify labeling and signage requirements.

FGA-ENV will coordinate with the Fire Department for quantity limitations, fire extinguisher, eye wash/shower, grounding/ bonding, communications, floor plans, evacuation routes and other requirements.

(c) Facility managers shall ensure hazardous waste amounts remain below 55 gallons for each satellite collection area and that an accumulation start date is noted on the label when the drum is full or on the container that is holding the excess accumulation of hazardous waste when the area exceeds 55 gallons.

(d) Facility managers shall call FGA Hazardous Waste Contractor,

(907) 873-1007, immediately when a hazardous waste drum is full

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(e) Facility managers shall ensure proper segregation of incompatible materials and wastes at all times. The following are not stored together: Flammables with corrosives or oxidizers, poisons with corrosives, caustics with acids.

(f) Reactive, corrosive, and flammable wastes shall be at least 50 feet from areas with unrestricted access.

(g) Facility managers shall post signs in each SAA as required by

FGA-ENV. The information includes emergency spill notification, updated personnel contact lists, hazard class designation, no smoking and a diagram of the area where hazardous material and waste are stored.

(h) Facility managers shall ensure labels and signs are clearly visible and easily read on all hazardous waste collection areas and containers, and that the areas are clean and materials are being collected in proper containers.

(i) Facility personnel shall immediately respond to spills and provide notification in accordance with the Spill Response and Notification Procedures provided in Chapter 5 of the FGA Environmental Procedures.

(j) Facility managers shall designate in writing primary and secondary custodians to be responsible for each SAA and provide FGA-ENV with copies of the designations. Ensure the custodians are trained and notify FGA-ENV of any change in assigned personnel.

(k) Facility managers shall maintain and store an adequate quantity spill response supplies (pads, booms, absorbent, etc.) to contain the worst-case spill scenario and at or near the SAA.

(l) Facility managers shall segregate waste types (see Attachment 3) and never mix a known or potential hazardous waste with a non-hazardous waste.

(m) Facility managers shall provide information as required to FGA-

ENV or the Hazardous Waste Management Contractor including MSDS’s and waste profile data.

(n) Typical wastes and their classification are provided in Attachment

3.

(o) Facility managers shall prior to attempting any management, cleanup, or disposal of unknown wastes, contact FGA-ENV for

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(p) If drums are stored outside, they must be covered in a manner to prevent accumulation of intrusion of rain and have secondary containment.

(q) The SAA Manager/Alternate will perform weekly inspections of their designated SAA (see Attachment 5).

(4) Container Standards

(a) The containers shall be labeled with the waste identity and a hazardous, non-hazardous, or universal waste label in accordance with 40 CFR 262.34(c)(1)(ii).

(b) Facility managers shall maintain a SAA Container Log of all waste additions (Attachment 4). The user must log in the type, quantity, and location from where the hazardous waste was generated on the accumulation container log.

(c) Facility managers shall assure that containers are not over-filled.

(Liquids should be no more than 3 to 4 inches from the top of a 55-gallon drum, 1.5 to 2 inches from the top of a 5-gallon can, 1 inch from the top of a 1-gallon can. Soils/solids should fill no more than ¾ of container.)

(d) Secondary containment, capable of containing 110% of the volume of the largest container, must be provided for all liquid hazardous waste containers ≥ 5 gallons. Overpack containers are suitable secondary containment for drums.

(e) Facility managers shall use the appropriate, compatible and properly marked/labeled collection containers.

(f) Facility managers shall collect only compatible waste in the same container.

(g) Incompatible materials shall be segregated from one another or in such a way that spilled material from one container may not contact the drip pan or container surface of another.

(h) Facility managers shall immediately replace damaged, dented or rusty containers that leak or may leak because of their condition.

(i) Facility managers shall keep containers clean on the tops and sides. Spilled materials and/or wastes will be cleaned up immediately and the cleaning material properly disposed.

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(j) Facility managers shall ensure drums containing flammable liquids are properly grounded and marked with a flammable sticker.

(k) Facility managers shall not use overpacks, salvage drums, 85/95-gallon, or unapproved containers as waste receptacles.

(l) Facility managers shall use new or properly cleaned containers provided by the Hazardous Waste Contractor for collection of waste materials. Hazardous waste placed in a used container shall be the same as original material.

(m) Facility managers shall maintain correct labeling of wastes in accordance with guidance provided by FGA-ENV.

(n) Facility managers shall ensure labels are clearly visible and legible at all times, facing outward, not toward center of pallet.

(o) Facility personnel shall use funnels to transfer liquids where practical to prevent spills. Funnels used to transfer flammable or volatile organic liquids shall be equipped with a spark arrestor, cover, and closure devices.

(p) Facility personnel shall watch the liquid level in the container carefully and do not leave containers unattended when filling (i.e., do not start a transfer pump and then leave the area).

(q) Hazardous waste containers will be kept closed (more than finger tight) at all times except to add or remove hazardous waste.

(r) Facility personnel shall secure proper bungs, plugs, and lids tightly prior to movement of the containers on site.

(s) Accumulation Start Date (ASD) must be clearly marked on the container. The ASD is the day the last drop of waste is added to the container.

(t) For containers of hazardous waste, the words “Hazardous Waste” must be clearly marked on the outside of the container.

(u) For containers of used oil, the words “Used Oil” and “Non-

Hazardous Waste for Energy Recovery and Recycling” must be clearly marked on the outside of the container.

(v) Used oil drip pans, drain buckets and tank fill pipes must be clearly marked “Used Oil”.

c. On-site Hazardous Waste Movement

The FGA HWMC is responsible for following the operational requirements of this

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(1) Provide generators with properly labeled and appropriate waste containers as requested.

(2) Remove hazardous waste from SAAs within 72 hours of being notified of a full container.

(3) Move containers in a safe manner to prevent accidents and spills.

(4) Inspect all containers prior to offsite shipment for proper packaging, labeling and condition.

(5) Notify FGA-ENV whenever discrepancies involving containers or documents are noted with any shipment through the DRMO waste contractor.

d. Temporary Hazardous Waste Accumulation Facility (THWAF) Management

The FGA HWMC is responsible for complying with the following operational requirements. The FGA HWMC shall:

(1) Ensure that the Hazardous Waste Accumulation Facility is sized, designed and constructed for accumulating waste covered by this procedure.

(2) Ensure that the facility has provisions for preventing snow, ice and rain accumulation on and under containers.

(3) Ensure the has no drain valves, floor drains, expansion joints, sewer lines, or other openings that would allow liquids to flow from secondary containment fixture may be present unless flow can be blocked, halted and controlled, such as through use of a locking drain plug.

(4) Ensure that authorized personnel and emergency response personnel have access to the containers. The container labels must be clearly visible and legible.

(5) Ensure that rows will be no more than two containers wide, with a minimum of three feet between rows. Aisles must allow for easy inspection of all containers for damage, leaks and spills, labels, and unobstructed movement of emergency equipment.

(6) Ensure that if containers must be stacked because no other option exists, then stack containers only to the extent that it is safe. Stack drums no more than two high. Follow stacking requirements of package/container vendor.

(7) Ensure that hazardous waste is moved off FGA property within 180 days of the accumulation start date. Universal Waste must be moved off FGA property within one year of the accumulation start date.

(8) The HWMC will track waste quantities by type to ensure Small Quantity Generator (SQG) quantity limitations are not exceeded at any given time.

(9) Ensure that adequate venting and ventilation is provided for all storage areas storing flammable or combustible materials.

(10) Ensure that the facility is secured to prevent unauthorized entry or tampering with the containers.

(11) Ensure that only materials and equipment required for consolidation, sampling, packaging and transportation of waste are stored in the

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THWAF.

(12) Ensure that warning signs are posted on all sides of the THWAF perimeter and are legible from a distance of 50 feet.

(13) Ensure that evacuation routes and a waste placement plan is posted in the

THWAF. Ensure that portable fire extinguishers, fire control equipment and water of adequate volume and pressure for water hoses are available at the THWAF. Ensure that personal protective equipment (e.g., respirators, gloves, and safety glasses) are readily available and used by all personnel under appropriate conditions.

(14) Ensure that all waste containers received are numbered, dated, and logged into a waste management log.

(15) Ensure that waste streams are sampled if adequate process or generator knowledge does not exist or the previous sample was at least two years ago. Analytical results will be reviewed and profile changes will be made as necessary. In addition, changes in disposal of waste streams will be made as necessary after analytical review. All new waste streams will be tested to determine chemical profiling. A sample will be collected and analytical data will be reviewed on each waste stream to determine that the process or the chemical constituents have not changed.

(16) PCB waste uniform manifest will include all weights of PCB wastes listed kilograms and the out of service dates (the PCB item with the oldest out of service date in the container should be listed).

(17) Maintain tracking information on the disposition of all waste from FGA.

This information includes document number, drum number, date shipped, generator, container log, manifests, exception letters and other applicable disposal documents.

5. Training The following required training is provided by or facilitated by FGAENV.

a. All personnel including contractors and tenants must complete the following:

(1) Environmental Management System Awareness

(2) Contractors must provide spill notification training to all personnel working under their control.

b. Chemical users must complete the following:

(1) Hazard Communication (HAZCOM).

(2) Contractors are responsible for ensuring that their employees have received HAZCOM training prior to using any hazardous materials.

c. Hazardous Waste/Materials Managers and Alternates must complete the following:

(1) 8 hour Subject Matter Expert Course

d. Supervisors and managers with dispensing or waste accumulation areas must complete the following:

(1) 8 hour Annual Refresher Training

e. Waste transporters and handlers:

(1) Hazardous materials transportation course

(2) Waste Handler Course

(3) 8-Hour Annual Waste Handler Refresher

f. Anyone required to wear a respirator:

(1) Respiratory protection training

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(2) Medical clearance and fit testing

6. Surveillance

a. Department, tenant or contractor Facility managers shall conduct daily visual inspections of dispensing and waste collection sites when in use for general housekeeping, leaks, container deterioration, or other problems. Facility managers shall conduct and document weekly inspections of hazardous material dispensing/storage areas.

b. HWMC The HWMC shall conduct and document weekly temporary storage facility inspections.

(Attachment 5) and perform comprehensive quarterly inspections of all SAAs and the THWAF and provide inspection reports to FGAENV.

c. FGA Environmental Coordinator FGAENV shall conduct frequent inspections of dispensing areas and SAAs. A notice of environmental deficiency may be issued for any discrepancy. Organizations must promptly correct any deficiencies.

7. Record Keeping

a. Department, tenant or contractor conducting governed activity.

For those areas that maintain both a Hazardous Material Storage Area and a SAA, one binder with the following criteria will suffice.

Hazardous Waste/Materials Managers of hazardous materials dispensing/storage areas or SAAs will maintain an “Environmental Notebook” on-site or in close proximity to the site. The Environmental Notebook must be readily available to area personnel. The notebook shall include, but is not limited to, the most recent versions of the following documents:

(1) FGA contacts list;

(2) FGA Environmental Procedure, Chapters 2 – Hazardous Materials and Waste Management;

(3) FGA Environmental Procedure, Chapter 5 – Spill Notification and Response;

(4) Personnel training records;

(5) Letters of Appointment for HM & HW Managers;

(6) Emergency Contact List;

(7) Emergency Response Drill record (HAZCOM unit level);

(8) Updated/Accurate Hazardous Materials Inventory;

(9) Container Logs/ Receipt of Hazardous Waste, Universal or Non-Regulated

Waste picked up by the HW contractor;

(10) Weekly HM and HW storage area inspection checklist and corrective action;

(11) Hazardous Waste & Materials Compliance Inspection Checklist

(Quarterly) report and corrective action;

(12) Facility Site Map/ Floor Plan.

b. HWMC will maintain:

(1) Copies of training records;

(2) Container logs;

(3) Records of each inspection;

(4) Copies of all waste analysis and other waste determination data;

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(5) Records of waste profiles;

(6) Copies of all waste manifests, and Letters of Exception, as applicable;

(7) Copies of land disposal restriction certificates, as required by 40 CFR

268.7;

(8) Copies of DD Forms 1348, generated by the tracking database.

c. FGA Environmental Coordinator will maintain:

(1) A database of all hazardous waste accumulation areas and satellite accumulation points;

(2) Copies of hazardous material inventories;

(3) Copies of inspection reports and findings generated by FGA-ENV;

(4) Copies of correspondence, inspections, findings received from state and federal regulatory agencies and copies of all correspondence and submittals from FGA-ENV to state and federal regulatory agencies;

(5) Emergency contact lists.

8. Reporting

a. The FGA ENV will submit the EPCRA Tier II Report to the Fire Department, Local Emergency Planning Committee, and Alaska Department of Environmental Conservation (ADEC). The report is due annually by March 1.

b. The FGA ENV will submit the EPCRA Form R report, if required, to the ADEC annually by July 1.

9. References

a. 40 CFR Part 261, Identification and Listing of Hazardous Waste

b. 40 CFR Part 262, Standards Applicable to Generators of Hazardous Waste

c. 40 CFR Part 263, Standards Applicable to Transporters of Hazardous Waste

d. 40 CFR Part 265, Subpart I, Use and Management of Containers

e. 40 CFR Part 265, Subpart CC Control of Air Emissions from Containers

f. 40 CFR Part 302, EPA Designation, Reportable Quantities, and Notification

h. 40 CFR Part 761, Management of PCBs

i. 49 CFR Parts 100 - 177, Subchapter C, Hazardous Materials Regulations

j. 29 CFR Part 1910.1200, Hazard Communication

k. AR 200-1, Environmental Protection and Enhancement

9. Attachments

a. Attachment 1 – Semi-annual Hazardous Material Inventory

b. Attachment 2 – Weekly Hazardous Material Dispensing/Storage Area Inspection

c. Attachment 3 – Identifying Hazardous Materials and Regulated Waste (24 pages)

d. Attachment 4 – Container Log

e. Attachment 5 – Weekly Inspection Form

f. Attachment 6 – Hazardous Waste and Materials Compliance Inspection Checklist

Ft. Greely Alaska

SEMI-ANNUAL HAZARDOUS MATERIAL

INVENTORY

Container Trade Name Part #

Manufacturer Size Type

Max # of Containers

Compatibility Group

MSDS?

Y or N

Facility # Storage Area Designation

Department:

Date:

Hazardous Materials and Waste Management Procedure, Revision 5: Attachment 1 – Semi-annual Hazardous Material Inventory January 2008

[Printed Copies of this Document for Operational Use Only – Controlled Electronic Document Available from DPW Environmental Office]

Hazardous Materials and Waste Management Procedure, Revision 5: Attachment 2 – Weekly Inspection Record January 2008

[Printed Copies of this Document for Operational Use Only – Controlled Electronic Document Available from DPW Environmental Office]

Weekly Hazardous Material Dispensing/Storage Area Inspection Record

Date: Location: Organization:

Inspected by: Signature:

Containers Yes No Are all containers 5 gallons or greater stored within secondary containment?

Are containers handled and stored to prevent rupture and/or leakage?

Are incompatible materials (flammables, acids, bases, reactives, and oxidizers) stored separately?

Gas cylinders secured so they will not tip over or fall with valve caps in place on cylinders that are not in use?

Container General

Are flammable containers stored away from ignition sources?

Yes No Are containers tightly closed, if not in use?

Are containers in good condition? (Replace damaged, dented or rusty containers)

Container Condition

Are containers free of leaks?

Yes No Are containers labeled with the product name and general hazards?

Are secondary use containers labeled with the product name and general hazards?

Are empty containers ≥ 5 gallons that were previously used marked “Empty”?

Container Marking

Are all labels legible?

Dispensing Storage Area

Yes No Is the area clean and spill-free?

Is spill response equipment adequate, compatible with the materials stored, and easily accessible?

Are signs posted and legible (Dispensing/ Storage Area, Spill Reporting, etc.)?

Are materials dispensed First In – First Out to reduce chemical waste?

Are Material Safety Data Sheets for all chemicals available?

Materials stored to prevent sliding, falling, or collapse?

Is storage shelving secure, in good condition, and not over-loaded or crowded?

Fire extinguishers located where flammable or combustible liquids are used?

Have expired materials been removed for appropriate disposition?

If any of these questions were marked NO, comment and describe action taken to correct situation.

Attachment 3

IDENTIFYING HAZARDOUS MATERIALS AND REGULATED WASTE

The purpose of this section is to list by common name some of the hazardous materials and regulated waste generally found on Ft Greely, Alaska and describe how to identify and process them. Materials and wastes are discussed below in alphabetic order.

• "Wastes must be correctly identified, properly packaged, and correctly labeled and marked prior to pick-up by Hazardous Waste Management Contractor (HWMC). It is imperative, prior to the scheduled pick-up day that the Hazardous Waste Contractor is notified of the type and quantity/volume of Hazardous Waste or Hazardous Materials anticipated. (If the source or parent product of the waste is well known or reasonably certain, the MSDS for that product must be submitted with the waste container). The HWMC will then provide and deliver to the facility a sufficient number of approved containers and will properly label those containers prior to on-site delivery. Contact FGA-ENV for details on packaging, labeling, and marking.

1. ABSORBENT PADS, USED

a. Identification. Absorbents used in drip pans, to clean up spills, or wipe containers and equipment.

b. Classification. Prior to use/storage: Not applicable When disposed: May be FLAMMABLE or COMBUSTIBLE based on testing. Contact FGA-ENV for determination.

c. Pollution prevention. POL-contaminated materials must be drummed and kept separate from chemical-contaminated materials. POL-contaminated absorbent pads, rags, dry sweep and debris may be mixed in the same drum, but not with contaminated soil. There must be no free liquids in the container.

d. Testing. Contact FGA-ENV for testing requirements.

e. Packaging. POL-contaminated materials can be packaged in steel or polyethylene drums.

f. Special equipment. Depends on contaminant in the absorbent.

Do FGA generators mark and label?

g. Disposal or recycling. Properly package, mark, and label waste. Call the HWMC to pick up and take containers to the collection point for off-site transportation and disposal.

Hazardous Materials and Waste Management Procedure, Revision 5: Attachment 3 – Identification List January 2008

[Printed Copies of this Document for Operational Use Only – Controlled Electronic Document Available from DPW Environmental Office]

2. AEROSOL CANS, EMPTY, DEPRESSURIZED

a. Identification. Includes aerosol cans that previously contained gaseous propellant, cleaning products, paint, enamel, lacquer, or other materials. Except for "acutely hazardous waste", aerosol cans are considered "empty" if they no longer contain more than 3 percent (%) of the original volume/net weight of contents. Aerosol cans are considered "depressurized" if the residual pressure of the contents is equal to or less than atmospheric pressure. Units/activities are advised not to attempt forced or deliberate depressurization of aerosol cans, such as punching a hole in the can, without proper approved equipment and procedures. The HWMC will depressurize aerosol cans at the Hazardous Waste Accumulation Area.

b. Classification. Prior to use/storage: Not applicable (SEE NEXT SECTION) When disposed: Scrap Metal

c. Pollution prevention. Use all material in the can. After each use, clean the spray nozzle by inverting the can and spraying to prevent clogging.

d. Testing. None identified.

e. Packaging. Contact the HWMC for requirements.

f. Special equipment. None identified.

g. Disposal or recycling. Call the HWMC to pick up and take containers to the collection point for depressurization and off-site transportation and disposal.

3. AEROSOL CANS, NOT EMPTY, PRESSURIZED

a. Identification. Includes aerosol cans that previously contained compressed air (or other gaseous carrier or propellant), cleaning products, paint, enamel, lacquer, or other materials. Except for "acutely hazardous waste", aerosol cans are considered "empty" if they no longer contain more than 3% of the original volume/net weight of contents.

Aerosol cans are considered "depressurized" if the residual pressure of the contents is equal to or less than atmospheric pressure. Units/activities are advised to attempt no forced or deliberate depressurization of aerosol cans such as punching a hole in the can without proper, approved equipment and procedures. The HWMC will make the determination if there is usable material remaining. If so, the material will be reused, if not, the container will be depressurized and the steel recycled.

b. Classification. Prior to use/storage: HAZARDOUS MATERIALS; may be

FLAMMABLE or COMBUSTIBLE, determined by contents.

When disposed: HAZARDOUS WASTE until recycled. Contact FGA-ENV for a case-specific determination.

Hazardous Materials and Waste Management Procedure, Revision 5: Attachment 3 – Identification List January 2008

[Printed Copies of this Document for Operational Use Only – Controlled Electronic Document Available from DPW Environmental Office]

c. Pollution prevention. Use all material in the can. After each use, clean the spray nozzle by inverting the can and spraying to prevent clogging.

d. Testing. Contact FGA-ENV for a case-specific determination.

e. Packaging. . Contact the HWMC for requirements pick up and take containers to the collection point for off-site depressurization and recycling or disposal.

4. ANTIFREEZE

a. Identification. Antifreeze products (usually ethylene glycol mixtures) are typically clear, or brightly colored (e.g., bright green, orange, or red), slightly syrupy liquids.

b. Classification. Prior to use/storage: HAZARDOUS MATERIAL When disposed: HAZARDOUS WASTE PENDING

ANALYTICAL RESULTS

When recycled: NON-HAZARDOUS WASTE FOR ENERGY

RECOVERY OR RECYCLING

c. Pollution prevention. Do not mix antifreeze with used oil or other petroleum products.

Typically, petroleum-contaminated ethylene glycol, or used oil that is contaminated with ethylene glycol, cannot be recycled and must be disposed.

Testing. Annual Stream verification required.

d. Packaging. Waste may be stored in any UN approved container.

e. Special equipment. None identified.

f. Disposal or recycling. Used antifreeze (ethylene glycol) may be recycled at the site if recycling equipment is available.

5. ASBESTOS

a. Identification. Asbestos may be present in many different products, including wall and ceiling insulation, pipe insulation, spray-on insulation, ceiling tiles, floor tiles, concrete, brake shoes, and gaskets.

b. Warning. Do not test, remove or dispose of asbestos yourself; contact FGA-ENV.

Asbestos testing, removal, packaging, and disposal must be performed by trained, certified asbestos workers. Do not perform asbestos abatement unless you are qualified

Hazardous Materials and Waste Management Procedure, Revision 5: Attachment 3 – Identification List January 2008

[Printed Copies of this Document for Operational Use Only – Controlled Electronic Document Available from DPW Environmental Office] and have been instructed by FGA-ENV to do so. The exception to this rule is asbestos-containing brake shoes. As long as the asbestos-pad on the brake shoe is intact (not "friable" - crumbling or falling away in pieces), the entire brake shoe should be double-bagged in 6-mil, polyethylene bags and discarded with non-hazardous solid waste for landfilling. The outer bag must have the following markings: a) name of the point of contact (POC), b) building numbers, c) the POC phone number, and d) identification of contents (i.e., "asbestos-containing brake shoes").

6. BATTERIES

a. Identification. Both rechargeable and non-rechargeable, INTACT batteries, including lead-acid, alkaline, nickel-cadmium, and lithium.

b. Classification. Prior to use/storage: HAZARDOUS MATERIAL; older lithium batteries may be FLAMMABLE.

When disposed: UNIVERSAL WASTE – USED BATTERIES, Alkaline are Non-Hazardous Waste, and Lead Acid are Hazardous Material. Do not disassemble batteries, since this often requires the parts to be managed as hazardous waste.

c. Pollution prevention. Minimize the use of batteries by using electrically powered equipment or rechargeable batteries, when possible. Do not disassemble the batteries, since this eliminates some recycling opportunities.

e. Packaging. DOT-approved container. Tape terminal ends if there is a possibility of a short circuit.

h. Warning. Do not break batteries open.

7. BATTERIES, BROKEN OR DISASSEMBLED PARTS

a. Identification. Batteries that have been taken apart (e.g., lead-acid batteries used in motorcycles, automobiles, and trucks that have had the metal core removed). However, discharging batteries to remove the electrical charge, regenerating used batteries, disassembling battery packs to remove individual batteries or cells, removing batteries from consumer products, or removing electrolyte from batteries are not considered disassembling.

Hazardous Materials and Waste Management Procedure, Revision 5: Attachment 3 – Identification List January 2008

[Printed Copies of this Document for Operational Use Only – Controlled Electronic Document Available from DPW Environmental Office] b.

c. Classification. Prior to use/storage: HAZARDOUS MATERIAL

When disposed: HAZARDOUS WASTE

d. Pollution prevention. Do not disassemble the batteries, since this eliminates the opportunity to recycle them and increases the regulatory requirements.

e. Testing. None identified.

f. Packaging. Use plastic containers for both the lead (metal) core and battery acid, since battery acid corrodes skin, eyes, clothing, steel, and aluminum.

g. Special equipment. At a minimum, wear rubber gloves and eye protection when managing lead acid batteries. A corrosive chemical-resistant apron is highly recommended. Battery acid often forms a white powder on the battery case that corrodes skin, eyes, clothing, steel, and aluminum.