Section_J_18_00_000-01_Environmental.docx

ATTACHMENT J-1800000-01

LIST OF ACRONYMS

J-1800000-01

ATTACHMENT J-1800000-02

OIL WATER SEPARATOR INVENTORY

Oil Water Separators shall be cleaned annually in accordance with the requirements of Spec Item 3.1.

Attachment J-1800000-02

81st Regional Support Command Louisiana Hazardous Material and Hazardous Waste Management Plan

November 2015

Prepared by:

US Army Institute of Public Health Waste Management Program Aberdeen Proving Ground, Maryland 21010

Requests for this document must be referred to Headquarters, 81st RSC 81 Wildcat Way Fort Jackson, SC 29207-6807

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Record of Annual Review This Hazardous Material and Hazardous Waste Management Plan must be reviewed annually by the 81st RSC Environmental Division Hazardous Material/Hazardous Waste Program Manager and the Louisianna Area Environmental Protection Specialist. The annual review should record the date the review was completed, the signature of the person who performed the review, and any applicable remarks.

Date Review Completed

TABLE OF CONTENTS

CHAPTER 1 INTRODUCTION 1

CHAPTER 2 MANAGING HAZARDOUS MATERIALS 13

CHAPTER 3 MANAGING REGULATED AND HAZARDOUS WASTES 33

CHAPTER 4 WASTE TURN-IN PROCEDURES 55

Chapter 5 Inspections, Reporting, Training, and RecordS 61

APPENDICES

TABLES

FIGURES

FORMS

CHAPTER 1

INTRODUCTION

1.1 HOW TO USE THIS PLANThis chapter describes the regulatory requirements for managing hazardous material (HM) and hazardous waste (HW) for the 81st Regional Support Command (RSC) facilities located in Louisianna.

This plan is formatted like an Army Technical Manual (TM), with easy-to-follow procedures. To use this plan, go to the table of contents to see which chapter contains the information needed and then go to the corresponding section of that chapter.

1.2 PURPOSE AND SCOPE

This Hazardous Material and Hazardous Waste Management Plan (HMHWMP) has been developed for 81st RSC organizations and activities located in the Commonwealth of Louisiana.

It provides information for those personnel who work directly with HM and HW in the performance of their duties. It applies to all organizations and activities under the command of the 81st RSC, including federal and state civilian employees (and contractors) who are not tenants of host installations. 81st RSC tenant organizations will comply with host installation HM and HW management policies and Standard Operating Procedures (SOPs).

This plan incorporates current Army, U.S. Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA), Department of Transportation (DOT), Department of Defense (DOD), Commonwealth of Louisianna, and 81st RSC requirements regarding the management of HM and HW as they relate to environmental protection and worker safety during operations.

The scope of this HMHWMP does not include:

· HM and HW Spills. Spill prevention and spill response is addressed in the 81st RSC PAM 200-1, the Facility Spill Contingency Plan (FSCP) or Spill Prevention Control and Countermeasure (SPCC) Plan (if one is required), or host Installation Spill Contingency Plan.

· Radioactive Material/Waste. Radioactive material/waste is addressed in the 81st RSC Regulation 385-2, Safety and Occupational Health. For instructions on proper disposal of radioactive items, contact the 81st RSC Safety and Occupational Health Office at 803-751-9790.

· Biomedical Waste. Some units generate sharps that are regulated as medical waste (infectious waste). For instructions on medical waste management, contact the 81st RSC Surgeon’s Office or the Area Environmental Protection Specialist (aEPS).

· General Refuse/Common Trash. General solid waste (SW) streams are not regulated as hazardous and do not pose an immediate threat to the environment. See the Louisianna 81st RSC Integrated Solid Waste Management Plan (ISWMP) for more information on the management of general SW streams.

1.3 REVIEWS AND REVISIONS

The 81st RSC Directorate of Public Works (DPW), Environmental Division Hazardous Material/Hazardous Waste Program Manager and the Louisianna aEPS are required to review this HMHWMP annually. All Environmental Compliance Officers (ECOs), as well as any other 81st RSC personnel or facility tenant directly involved in HM or HW management, are encouraged to provide comments and input to this plan. To do so, complete a Department of the Army (DA) Form 2028 located at the end of this chapter and forward it to the aEPS.

1.4 TECHNICAL ASSISTANCE

For technical assistance, contact the following offices identified in Table 1-1 below.

Table 1-1. 81st RSC DPW Environmental Division and Points of Contact.*

Greg Mason aEPS for xx

Daniel Thomas Environmental Division Chief

803-240-9747 (C) daniel.h.thomas12.civ@mail.mil

Linda Riley-Lattimore NEPA/NR/CR Program Manager

Paul Peterson HW Program Manager

Ken Burghardt Contractor, Alpha Facilities Solutions EPAAS Program Manager, Training

* List updated August 2015.

1.5 APPLICABLE REGULATIONS

The procedures described in this plan are required by federal, state, DOD, Army Regulations (ARs), and 81st RSC regulations and business operating practices. Conformance to this HMHWMP is subject to review during inspections by regulatory authorities such as the EPA and the Louisianna Environmental Quality Board (LAEQB). The procedures and guidance described in this plan are also evaluated during regularly scheduled internal and external environmental performance assessments.

Other requirements of AR 200-1, including requirements in other environmental areas such as toxic substances, are provided in the 81st RSC PAM 200-1. These and other documents may be accessed through the 81st DPW Share Portal https://usarbasops.ocar.army.pentagon.mil/sites/81RSC/default.aspx or by contacting the aEPS.

1.5.1 Federal Regulations

In order to comply with the Federal Facilities Compliance Act, 81st RSC personnel must manage HW in accordance with (IAW) the Resource Conservation and Recovery Act (RCRA) of 1976, as amended by the Hazardous and Solid Waste Amendments of 1984. The objectives of RCRA are to protect human health and the environment from the potential hazards of waste disposal, to conserve energy and natural resources, to reduce the amount of waste generated, and to ensure that wastes are managed in an environmentally sound manner.

The most important aspect of RCRA that affects the 81st RSC is its establishment of "cradle-to-grave" management and tracking of HW from generator to transporter to treatment, storage, and disposal. The federal waste management regulations are codified in Title 40 of the Code of Federal Regulations (CFR). This plan provides procedures for complying with the following parts of 40 CFR:

· Parts 260 through Part 272 for the regulation of HW.

· Part 273 for the regulation of universal waste.

· Part 279 for the regulation of used oil.

81st RSC personnel must also comply with the following federal requirements:

· Defense Transportation Regulations which incorporate by reference 49 CFR Parts 170 through 177 regarding HM transportation.

· 29 CFR Part 1910 regarding employee safety and health.

1.5.2 Louisianna Hazardous Waste Regulations

This HMHWMP addresses Federal regulations and those of the Commonwealth of Louisianna.

The EPA has not authorized the hazardous waste program in Louisianna. Therefore, the requirements of both the federal and commonwealth must be met. In instances where there are requirements for both, defer to the more stringent requirement.

For the purpose of the requirements and management practices established in this plan, the Louisianna HW and UW rules mirror the federal rules with the following exceptions or highlights:

· Hazardous secondary materials that are being reclaimed or used to make fertilizers

· Used cathode ray tubes

· Treatability study samples

· Non-terne plated used oil filters

· Used CFC refrigerants from totally enclosed heat transfer equipment

· Dredged materials

· Petroleum-contaminated media and debris

· Comparable fuels and comparable syngas fuels

· Certain spent wood-preserving solutions

By March 1 of each even numbered year, SQGs must submit a biennial waste report to LAEQB

· The number of tires that may be accumulated is contained in the permit

· Must have an emergency plan

· Must obtain insurance

· Must use a registered transporter and use the Automatic Manifest System when sending or receiving tires

Appendix D provides WPSs that describe waste-specific management and disposal requirements in consideration of Louisianna regulatory requirements, as applicable.

The only exceptions to this are those facilities who are tenants at larger host installations and subject to host installation Policy and SOPs.

1.5.3 Military Regulations

All personnel must comply with AR 200-1, which contains Army policy, goals, and requirements for HM and waste management. AR 200-1 requires that organizations:

“Develop and implement a hazardous waste management plan (HWMP) or other comparable document appropriate to the size and complexity of the operation. The HWMP (or other comparable document) should include, at a minimum, written procedures for all aspects of HW management, to include the identification, storage, and transporting of HW; training of personnel; tracking manifests; and maintaining required records.”

This plan is designed to fulfill the requirements of AR 200-1; specifically, the elements of Chapter 9, Materials Management, and Chapter 10, Waste Management.

DOD Instruction 4715.6, Environmental Compliance, implements policy, assigns responsibility, and prescribes procedures for achieving compliance with applicable Executive Orders, federal, state, inter-state, regional, and local statutory and regulatory environmental requirements.

In addition, 81st RSC personnel must comply with approved standardized HM management business practices as specified by Headquarters, DA, G-4. Army logistics policy must be followed for identifying, storing, and transporting HM. Related policy guidance can be found in safety, medical, acquisition, and logistics regulations. These regulations and policies include but are not limited to:

· DOD Regulation 4500.9-R, Part II, Chapter 204, Defense Transportation Regulation.

· AR 710-1, Centralized Inventory Management of the Army Supply System.

· TM 38-410, Storage and Handling of Hazardous Material.

· Field Manual 3-34.5/MCRP 4-11B, Environmental Considerations.

1.6 RESPONSIBILITIES

This section identifies the positions and describes the responsibilities for those working directly with HM and/or HW. The responsibilities described below are consistent with those in the 81st RSC PAM 200-1, but do not include those responsibilities associated with upper management duties (e.g., Environmental Quality Control Committee) or that are non-HM/HW related. For a comprehensive description of all environmental responsibilities and duties, see the 81st RSC PAM 200-1.

1.6.1 Unit Commanders/Facility Coordinators/Environmental Compliance Officers

Unit Commanders/Facility Coordinators/ ECOs are responsible for ensuring:

· Accountability of all HM and HW.

· Proper disposal of all HW generated at the facility or within the unit.

· Facility Coordinators have received proper training within 180 days of assuming their duties and receive annual refresher training.

· The unit ECO and alternate ECO are appointed in writing.

· Environmental management programs meet all regulatory requirements.

· Personnel exposed to HM in the course of their work are aware and properly protected.

· When unit ECOs are deployed, the alternate ECO assumes the responsibilities.

1.6.2 Facility Coordinators and AMSA Supervisors

Facility Coordinators and AMSA Supervisors are responsible for:

· Acting as the HM/HW spill coordinator and ensuring spills are immediately contained.

· Coordinating training for all personnel who come into contact with HM/HW within the normal course of their duties.

1.6.3 Motor Sergeants and AMSA Supervisors

Full time unit motor sergeants and AMSA Supervisors who are directly involved in the handling and/or overseeing of HM and HW are responsible for:

· In coordination with the aEPS and safety representative, designating HM and HW storage areas and inspecting them monthly.

· Ensuring each type of HW generated is accumulated in separate containers.

· Labeling of HW containers.

· Ensuring used oil and antifreeze are collected properly and turned-in.

· Ensuring stock levels of HMs are kept at a minimum.

· Replacing toxic materials with less toxic materials whenever available and feasible.

· Ensuring the washrack and oil/water separator (OWS) are properly used and maintained.

· Ensuring the facility has adequate spill response equipment, containers, labels, and placards.

· Recycling wastes and minimizing waste generation whenever possible and feasible.

1.6.4 Facility Coordinator/Unit Environmental Compliance Officer

The following duties are the responsibility of the Facility Coordinator/ECO:

· Completing ECO training.

· Advising the Commander on all environmental issues.

· Ensuring training conducted on drill weekends is done IAW environmental laws and regulations.

· Training unit personnel on their environmental responsibilities.

· Maintaining an environmental training file for unit personnel.

· Maintaining the following required environmental management records for a minimum of 3 years:

· HM/HW Inventory

· Quarterly Hazardous Waste Generation Report

· Monthly Hazardous Material/Hazardous Waste Inspection Checklists

· Container Hazardous Waste Accumulation Logs

· HW Profile Sheets

· Regulatory Inspection Reports

· Spill Reports

· Environmental Training Records

· Storage Tank Monitoring Reports

· Safety Data Sheets (SDSs) for each chemical

· Maintaining HM and HW storage areas with proper separation of incompatible materials and wastes.

· Tracking HMs and HWs from receipt to disposal.

· Maintaining current year HW manifests on file and archiving prior years indefinitely.

· Providing, upon request, 81st RSC HQ and aEPS with the information necessary to prepare reports for regulatory agencies, the Army, and DOD.

1.6.5 Unit Supply Sergeants

Unit supply sergeants are responsible for:

· Ensuring that the facility has adequate HW management supplies.

· Arranging for turn-in of HW generated during the training exercise at host installations during training exercises.

· Ensuring SDSs are received for all HM obtained.

· Submitting copies of SDS to the ECO.

· Maintaining SDSs where HM and HW are stored.

1.6.6 Unit Chemical, Biological, Radiological and Nuclear (CBRN) Sergeant

The CBRN sergeant is responsible for:

· Turning in waste decontamination solutions and super tropical bleach (STB).

· Turning in all mask filters and expended DECON (decontamination) kits as HW, where applicable.

1.6.7 Prescribed Load List (PLL) Clerk

The PLL clerk is responsible for:

· Requisitioning mercury and lithium batteries with recoverable code “A” only when a like item and quantity have been turned in for exchange.

· Managing hazardous batteries, that are not eligible for one-to-one exchange, as UW.

1.6.8 Area Environmental Protection Specialist

The aEPS is responsible for:

· Conducting facility site visits and assessing whether facility occupants are properly storing HM/HW. If deficiencies are observed, provide guidance on proper storage techniques to personnel.

· Ensuring waste determinations are made as soon as possible.

· Characterizing waste streams by applying knowledge of the materials (SDS and/or labels) or by requesting a chemical analysis.

· Using the Defense Logistics Agency Disposition Services (DLA-DS) for HW disposal.

· Using Web Application System for Turn-In Execution (WASTE) to generate waste profiles, Disposal Turn-In Documents (DTIDs), requesting HW disposal from DLA-DS, and following all software and RSC procedures.

· Coordinating with facility representatives, in advance of waste pick-ups, to ensure waste contractors are able to access facilities and waste storage locations.

· Attending and overseeing waste pickups at facilities to the maximum extent possible and signing HW manifests “on behalf of” the 81st RSC. If not able to be present, arranging for a qualified alternate to be on site. “Qualified” means individuals have met the DOD training requirements to sign an HW manifest.

· Notifying Plateau Software Inc. Program Analyst to delete any DTIDs from WASTE that were cancelled and did not result in an HW pickup.

· Maintaining HW records IAW 81st RSC procedures as well federal and state requirements.

· Completing EPA and state applicable annual or biennial reporting requirements.

· Receiving initial and refresher training every 2 years IAW DOD Reg. 4500.9 R, Part II, Chapter 204 to sign HM and HW shipping documents/manifests.

· Completing Defense Logistics Agency (DLA) Menu of Services to facilitate contract solicitations.

· Completing EPA Form 8700-12, Notification of Regulated Waste Activity (or state equivalent), for facilities which require an EPA RCRA identification (ID) number and submitting it to the HM/HW Program Manager for review, the Environmental Division Chief for signature, and the applicable state agency for processing.

1.6.9 Facility Operation Specialists [regional Facility Operation Specialist (rFOS) and Area Facility Operation Specialist (aFOS)]

The rFOS and aFOS are responsible for:

· Disposing of HW generated under service, facility maintenance, and construction contracts. Potential HWs include, but are not limited to construction and demolition waste, paints, contaminated soil, waste lamps, waste batteries, and sludge from wash racks and OWSs.

· Incorporating into facility maintenance and construction contracts a requirement for the contractor to document how many pounds of each HW and UW were generated and disposed of as a result of the contract for each calendar year.

· Providing copies of the contactor’s waste manifests to the aEPS.

1.6.10 HQ 81st RSC DPW Environmental Division HM/HW Program Manager

The 81st RSC HM/HW Program Manager is responsible for:

· Coordinating with the aEPS for HW turn-in.

· Developing and maintaining the electronic version of the state HMHWMP.

· Facilitating creation of Command HW policies.

· Programming annual funding for HW disposal and tracking execution (obligations and disbursements).

· Engaging higher headquarters and other agencies (DLA, Defense Finance and Accounting Services, EPA Regions 4 and 6, and each state’s Environmental Divisions) as required for resolving problems and validating information and procedures.

· Reviewing and negotiating all required DLA-DS Memorandums of Agreement.

· Reviewing the Comparison Report in WASTE application and approving the changes to acknowledge the discrepancies.

· Reviewing documentation for termination of EPA ID numbers and submitting it to the appropriate 81st RSC official for signature.

· Reviewing monthly reports from WASTE and program analyst’s feedback regarding data integrity. Determining root cause(s) of any identified problems and identifying and initiating corrective actions to prevent such problems in the future.

· Tracking and submitting HW Measures of Merit via the Army Environmental Database-Environmental Quality.

· Reviewing and submitting DLA-DS Menu of Services for contract solicitations.

1.7 FORMS AND INSTRUCTIONS

This section contains the following form:

· DA Form 2028, Recommended Changes to Publications and Blank Forms.

CHAPTER 2

MANAGING HAZARDOUS MATERIALS

Nearly all 81st RSC facilities use HMs, which are essentially those items requiring an SDS; that is, materials that have been determined to be capable of posing a risk to health, safety, and property when transported in commerce. This chapter provides detailed steps for properly managing HM. These steps comprise a system that allows the user to prevent and/or reduce waste generation and ensure the safety of facility personnel. Regulatory requirements incorporated into this chapter are from 29 CFR 1910.1200 Hazard Communication (HAZCOM) Standard, National Fire Protection Association (NFPA) Standards, DODI 6050.05 HAZCOM Program, and 81st RSC PAM 200-1.

2.1 IDENTIFYING UNSERVICEABLE AND EXCESS HAZARDOUS MATERIAL

Before establishing permanent HM storage areas, all unserviceable and excess HM must be removed from the facility. Removal of these items will:

· Increase storage capacity

· Minimize safety hazards

· Help prevent spills

· Reduce HW generation

NOTE: Do not hoard HM. Hoarding creates storage problems and eventually, waste disposal issues. Always turn in unserviceable and excess HM items in a timely fashion.

To identify and remove unserviceable and excess HM, complete the following steps:

Step 1. Walk around the entire facility and check closets, wall lockers, storage rooms, CONEXs, etc., for excess and unserviceable HM. Collect containers that are:

· Unlabeled or contain unidentifiable materials

· Damaged or leaking

· Expired shelf-life items

NOTE: Type I shelf-life items cannot be extended and must be turned in as waste when expired. Type II shelf-life items may be extended. Contact the aEPS for guidance on expired shelf-life products.

Step 2. Establish an interim accumulation area for unserviceable and excess HM. Materials must be evaluated to determine if they are an HW. See Chapter 3, Managing Regulated and Hazardous Wastes, for more information. If a proper HM storage area is not available, an interim accumulation area may be created using the following procedures:

· Clean out an existing shed or building and remove any combustible items including trash, wood, incompatible materials, and any other unnecessary items.

· Absorb and remove any free product and dispose of properly.

· Line the floor with plastic sheeting (without breaks, or tears) and carry it up the sides of the wall at least 6 to 8 inches, forming a dike/lip.

· Line the walls with sand bags, including the doorway.

· Construct a ramp over the sandbags in the doorway to allow for free egress into and out of the building.

· Provide spill response equipment compatible with the materials stored, which is required. The equipment must be located near the storage area where it can be easily obtained in case of a spill or release.

· Follow the procedures outlined in this chapter for accessibility of SDSs, compatibility, aisle spacing, fire extinguishers, labeling/placarding, and signage.

Step 3. Process the collected items for turn-in IAW Chapter 4, Waste Turn-In Procedures.

2.2 MAINTAINING SAFETY DATA SHEETS

SDSs are required for each HM stored at the facility. They provide information about:

· Compatibility

· Manufacturer

· Chemical Ingredients

· Associated Hazards

· Specific Handling Procedures

· Spill Response Measures

NOTE: SDSs must be accessible at all times for review by employees and emergency response personnel. Under OSHA, employees must be familiar with the hazards of a material and have the right to review SDSs at any time. As such, the SDSs must be maintained in a common area that is unlocked and readily accessible at all times.

Obtain and catalog SDSs by completing the following steps:

Step 1. Obtain the SDS furnished by the manufacturer. This SDS should accompany the product when it is received.

Step 2. If an SDS did not come with the product, obtain it from the Hazardous Materials Information Resource System (HMIRS) by accessing http://www.dlis.dla.mil/hmirs/.

Step 3. If the SDS is not available from HMIRS, obtain a copy by accessing any of the free sites found at http://www.ilpi.com/msds/.

Step 4. If the SDS is not available through SDS Search, request assistance from the aEPS or contact the manufacturer.

Step 5. Maintain SDSs near the area where the HM item is stored and used.

Step 6. Create a master binder with all SDSs and centrally locate it so an SDS can be located quickly in case of a spill or exposure.

Step 7. Create an index in the front of the binder listing all the SDSs. Organize them in an order such that they can be easily located.

2.3 DETERMINING HAZARDOUS MATERIAL COMPATIBILITY

HMs must be segregated according to their hazards; the type of hazard will also determine storage requirements. For example, flammable materials must not be stored with corrosives or oxidizers. The hazard will be identified on the container itself or on the SDS. HM items determined to be incompatible (i.e., a strong acid and an organic solvent) must be separated by a dike, berm, wall, or by storing each material in separate secondary containment capable of holding 100 percent of the product in the event of a leak or container failure. Contact the aEPS or HM/HW Program Manager for assistance.

This section explains how to determine compatibility by using one of the three following methods:

· Method 1: Determining compatibility using HMIRS-generated SDSs.

· Method 2: Determining compatibility using DOT hazard labels.

· Method 3: Determining compatibility using OSHA precautionary labels.

2.3.1 Method 1: Determining Compatibility Using HMIRS-Generated SDSs

When using the HMIRS SDSs for determining compatibility, implement the following steps:

Step 1. Find the Hazard Characteristic Code (HCC) in the Transportation Information section (see Figure 2-1).

Step 2. Use Appendix A, Storage Segregation Matrix, to find the matching HCC located in the far left column.

Step 3. Follow the row across the table and locate the * (star) marking.

Step 4. Follow the column up from the * marking to the Primary Segregation Letter. These letters stand for the following:

Figure 2-1. SDS Showing HCC.

DOT RQ:

Limited Qty:

Marine Pollutant:

Magnetic Material:

Magnetic Strength:

EX #:

Net Explosive Weight:

Net Propellant Weight:

Department of Defense ID Code:

High Explosive Weight:

Net Explosive Qty. Distance Weight

-20 C

Additional Information:

TRANSPORTATION PER MSDS.

Step 5. HM items may only be stored with items that have the same primary segregation letter. For example, store Fs with other Fs (flammables with other flammables) and Cs with other Cs (corrosives with other corrosives).

Step 6. In Appendix A, return to the HM’s HCC row and find the “Note” under the Secondary Segregation column. Implement any additional segregation requirements identified at the end of the matrix.

Example

A facility has an HM with an HCC of F6 (a corrosive acid that is flammable) and an HM with an HCC of F7 (a corrosive alkali that is flammable). Because they are both Fs, it first appears that they could be stored together. However, they both have a secondary segregation note of L, which states, “Separate from other flammables and flammables with secondary hazards by at least one 4-foot aisle width.”

2.3.2 Method 2: Determining Compatibility using DOT Hazard Labels

If an HMIRS-generated SDS is not available, use the item’s DOT hazard label to determine compatibility by completing the following steps:

Step 1. Look at the DOT hazard label on the container or the box in which the HM was shipped. Refer to Figure 2-2 below for examples of DOT labels.

Figure 2-2. Sample DOT Labels.

Step 2. Using Table 2-1, determine the interim HCC of the HM based on the DOT hazard label.

Table 2-1. DOT Hazard Labels and Associated Interim HCC.

Step 3. Using Appendix A, Storage Segregation Matrix, follow Steps 2 through 6 under Method 1 in Section 2.3.1 to determine compatibility.

2.3.3 Method 3: Determining Compatibility Using OSHA Precautionary Labels

If an HMIRS-generated SDS or a DOT hazard label is not available, follow the steps below to determine compatibility using an OSHA precautionary label.

Step 1. Look on the HM container for an OSHA precautionary label. Precautionary labels start with signal words followed by specific handling precautions. The three signal words used are Danger, Warning, and Caution. See Figure 2-3 below for an example.

Figure 2-3. Example Precautionary Label.

Step 2. If a precautionary label is present, use Table 2-2 to obtain a suggested temporary HCC. Match the label with the “Signal Word” and “Statement of Hazard” in the first two columns of the table. The statement of hazard won’t always be exact. Choose the one that best describes the hazard.

Step 3. Using Appendix A, Storage Segregation Matrix, follow Steps 2 through 6 under Method 1 in Section 2.3.1 to determine compatibility.

Table 2-2. OSHA Precautionary Labels and Associated HCC.

Temporary HCC

2.4 ESTABLISHING PERMANENT STORAGE AREAS

2.4.1 General Guidance

HM must be stored in one of the following types of units:

· Storage locker

· Storage room, building, or CONEX

· Storage rack

Select the appropriate type of storage unit for the HM:

· For small quantities (daily use of HM), select a storage locker.

· For large quantities (greater than 1 gallon) of HM, select a storage room or building.

· For dispensing HM in drums or “lube cubes,” use a rack.

Regardless of which type of storage unit is selected, all HM must be stored in a manner that:

· Minimizes the potential for spills and accidental releases

· Has controlled access

· Is protected from adverse weather conditions

· Provides sufficient aisle space for unobstructed movement of personnel and fire and spill control equipment in an emergency

· Provides primary and secondary containment. Secondary containment must be equal 10 percent of the total volume of all containers or 110 percent of the volume of the largest container, whichever is greater

National Fire Protection Association (NFPA) 704 placards must be placed on each structure that is used to store HM. The NFPA 704 placard must be placed at eye level and adjacent to the main entrance door. To determine the numerical rate/code for the placard, consult the SDS of each HM. See Appendix C, NFPA Hazard Ratings, for information on the numerical hazard ratings. The aEPS will provide the NFPA 704 placards and assistance on numerical ratings, if needed.

Each HM storage area should have a posted copy of the Spill Response Procedures provided in the 81st RSC PAM 200-1.

2.4.2 Storage Lockers

Storage lockers are intended for use in the immediate work area. They should be NFPA-approved and should contain only small quantities of HM to be used on a daily basis. General guidance for storage lockers includes:

· A room should not contain more than three lockers.

· Flammable lockers must not be used to store any other types of products/items other than flammable or combustible products.

Shelves within the lockers must be of sufficient depth and be provided with a lip or guard to prevent individual containers from being easily displaced.

NOTE: Lockers should not be “stuffed” with HM such that they become a tinderbox should a fire break out. Store excess containers of HM in storage rooms or buildings away from the work area.

IAW NFPA Code 30, venting of lockers has been demonstrated to be necessary for fire protection purposes. Normally, storage lockers within the 81st RSC will not be vented. Vent plugs will be installed and secured. If vented, lockers must be vented to the outside of the building and away from any source of ignition.

The three types of storage lockers used by the 81st RSC are color-coded for ease of ID by the Fire Department. Table 2-3 shows that the color depends on the material being stored. If the locker is an older version, repainting is not required.

Table 2-3. Locker Color Codes.

Use the lockers for their intended purpose. For instance, do not store non-flammables, such as antifreeze, in a flammables locker. Only store flammables/combustible materials in flammable lockers. Keep lockers clean and orderly, and maintain all structural integrity and hardware, including doors, hinges, and shelves. Do not remove the door or ventilation bungs, penetrate the wall, modify ventilation, or otherwise modify the locker. Always keep locker doors closed.

To set up a locker, complete the following steps:

Step 1. Select a location for the locker:

· Locate the locker indoors in a well-ventilated area near where the HM will be used.

· Maintain easy access to the locker; do not block doors or place personal items on top of the locker.

· Do not place the locker near doors, break rooms, bathrooms, offices, or other occupied non-shop areas.

· Do not place the locker near floor drains, drainage channels, or areas with high foot or vehicle traffic.

Step 2. Mark and label the locker. Coordinate with the aEPS to ensure that the locker is appropriately labeled. Do not place unauthorized signs, labels, stickers, or markings on the locker.

Step 3. Ensure that an appropriately rated fire extinguisher and spill response equipment are located nearby.

2.4.3 Storage Rooms, Buildings, and Racks

Storage rooms and buildings are intended for storage of large containers of HM (greater than 1 gallon). Storage racks typically are used for dispensing petroleum, oil, and lubricant (POL) products (e.g., lube cubes). Locate storage rooms, buildings, and racks away from the work area. Keep them clean and orderly, and maintain all structural integrity and hardware including doors, hinges, and shelves. Do not remove doors, penetrate walls, modify ventilation, or otherwise modify a room or building unless approved by appropriate personnel. To set up a storage room, building, or rack, complete the following steps:

Step 1. Have the aEPS and safety representative approve the location.

Step 2. Provide primary and secondary containment. Secondary containment should be 10 percent of the total volume of all containers, or 110 percent of the volume of the largest container, whichever is greater.

Step 3. Ensure that an appropriately rated fire extinguisher and spill response equipment are located nearby.

Step 4. Mark and label the storage area. Coordinate with the aEPS to ensure that the storage area is appropriately labeled. Do not place unauthorized signs, labels, stickers, or markings in the area.

2.4.4 Stocking a Hazardous Material Storage Unit

Before stocking or restocking, make sure all HMs entering the inventory are authorized for use. Use of the government International Merchant Purchase Authorization Card for purchase of HM is prohibited unless prior approval from the aEPS is obtained. Whenever possible, substitute products that are less or non-hazardous (“green” products) for products that are hazardous. See Appendix B, “Green” Products, for a list of suggested substitute products.

Step 1. Check the compatibility of HM items before placing them in any storage unit.

Step 2. Determine the amount of required shelf space (for lockers) and floor space (for rooms and buildings) needed for the storage of the HM.

Step 3. Ensure that all HM containers have labels and place them in the storage unit in an orderly fashion. Rotate the containers so that items that expire first are in the front.

Step 4. When stocking lockers, be sure not to exceed the following quantities. See Table 2-4 for classifications of flammable and combustible liquids.

· 60 gallons of Class I liquids

· 60 gallons of Class II liquids

· 120 gallons of Class III liquids

· 120 gallons of Class I, II, and III liquids combined

Table 2-4. Classification of Flammable and Combustible Liquids.

Step 5. When stocking rooms and buildings, do not exceed the following quantities. See Table 2-4 for classifications of flammable and combustible liquids.

· 60 gallons of Class IA liquids

· 120 gallons of Class IB liquids

· 180 gallons of Class IC liquids

· 240 gallons of Class II liquids

· 660 gallons of Class IIIA liquids

· 240 gallons in any combination of Class I and Class II liquids

When stocking storage units, be sure of the following:

· Containers holding HM must be closed during storage, except as necessary for product use. When not in use, bungs/covers of all containers must be tightly closed to prevent spills and releases.

· Careful removal of the material from the storage containers must be emphasized to avoid contaminating the exterior of the container and the surrounding area.

· Containers must be placed so that the labels and warnings can be read without moving the container.

All containers must be labeled or marked with information describing the HM it holds. If the original label or marking is missing or illegible, perform the following steps:

Step 1. Write the common chemical name of the material legibly and permanently on the container in a contrasting color.

Step 2. Write the National Stock Number (NSN) legibly and permanently on the container.

Step 4. Mark the proper DOT shipping name on the container. Contact the aEPS for assistance.

2.4.5 Container Handling

Containers with a capacity of 30 gallons or greater may not be stacked more than two containers high. Containers and stacks must be separated by pallets or dunnage to provide stability. Pallets/dunnage must be made of non-combustible material or of wood not less than 1 inch in thickness. The preferred method for storage of containers with bungs is the horizontal position. Open head drums should be stored in the vertical position; ensure drum heads/locking rings are in place and wrenched tight.

Empty containers that previously held flammable or combustible liquid must be stored in the same manner as full containers described above, unless they are free from explosive vapors. Empty containers must have the covers or plugs immediately replaced in the opening.

2.4.6 General Storage Requirements

Openings in interior walls to adjacent rooms or buildings and openings in exterior walls with fire-resistance ratings must have fire doors with fire-resistance ratings corresponding to the fire-resistance rating of the wall. Doors may be left open during material handling operations if the doors are designed to close automatically in a fire emergency. Except for drains, floors must be liquid tight and the area must be liquid tight where the walls join the floor. Contact the 81st RSC Safety Officer for assistance with fire rating questions.

Barriers must be provided under emergency conditions to prevent the flow of liquids into adjoining building areas. Secondary containment must be equal to 10 percent of the total volume of all containers or 110 percent of the volume of the largest container, whichever is greater. This must be accomplished by providing one or a combination of the following across the entire width of each opening:

· Non-combustible liquid-tight raised sills, curbs, or ramps of suitable height. The appropriate height for sills, curbs, etc., will depend on the maximum expected spill volume, the floor area, and/or the existence of any drainage systems.

· Open-grates.

· Any other acceptable method. Contact the aEPS for guidance, if necessary.

Spill response equipment must be maintained in or near the storage area. Flammable or combustible liquids must not be stored in a manner that limits use of exits, stairways, or areas normally used for the safe egress of people. Shelves must be of sufficient depth and be provided with a lip or guard to prevent individual containers from being easily displaced. Pallets/dunnage must be made of non-combustible material or of wood not less than 1 inch in thickness.

Drum stacks must be separated from each other by at least 4-foot aisles. Aisles must be provided so that all containers are 12 feet or less from an aisle. Main aisles must be a minimum of 8 feet wide. Stacks must not be closer than 3 feet to the nearest beam, chord, girder, or other obstruction, and must be 3 feet below sprinkler deflectors or discharge orifices of water spray or other overhead fire-protection systems. Additional aisles must be provided for access to doors, windows, ventilation, or switches. A minimum of 24 inches must be maintained between stacks and outside walls.

Class I liquids must not be stored in basement areas. Class II and Class IIIA liquids may be stored in basements; provided that automatic sprinkler protection and other fire protection equipment is provided. See Table 2-4 for classifications.

2.4.7 Fire Protection

Where automatic sprinkler protection is provided, barriers must be present to prevent the spread of burning liquids to other unaffected areas. It will be necessary to control the flow of liquids and safely remove it from the affected areas.

2.5 MAINTAINING AND TRACKING INVENTORY

Each activity on an 81st RSC facility must prepare an inventory and update it every 6 months, recording the results on the Hazardous Material/Hazardous Waste Inventory Form (see Section 2.6, Forms and Instructions). The inventory must include all products and waste (HM, HW, UW, Non-RCRA regulated waste) on hand that require an SDS including all materials stored in POL sheds and other buildings within the fence line. Also include bulk HM, such as diesel fuel, heating oil, JP-8, motor vehicle gasoline (MOGAS), and propane.

2.5.1 Conducting a Hazardous Material/Hazardous Waste Inventory

To conduct an inventory, complete the following steps:

Step 1. Verify each storage tank, container, bottle, can, box, etc., is labeled with the following:

· Product name

· Warnings of physical or health hazards listed on the SDS

Step 2. Replace any labels that are missing or unreadable.

Step 3. Check the expiration, inspection, or testing dates and manage IAW this plan if the HM is expired and has become a waste.

Step 4. Complete the Hazardous Material/Hazardous Waste Inventory Form. Do not include HM used for administrate purposes such as ink, toner, correction fluid, air freshener, etc.

Step 5. Send the completed HM/HW Inventory Form to the aEPS semiannually, by 15 February and 15 August each year. For those facilities that do not have any HM or HW, a negative response is required.

Step 6. Post a copy of the completed form next to each HM/HW storage unit (e.g., on the cabinet, building, or cage door).

Step 7. Keep the two most recent completed forms in the Environmental Records Binder (ERB); see Chapter 5, Inspections, Reporting, Training, and Recordkeeping, for guidance. HM/HW inventories must be performed at least twice a year and updated each time a new product is procured.

Step 8. Submit a copy of the latest HM/HW Inventory Form to the local fire department using a cover letter similar to the example provided in Figure 2-4. The Fire Department must know which chemicals are onsite, where they are stored, and in what quantities. With the HM/HW Inventory Form and the letter, include a simple map of your facility showing the locations of all HM/HW. Notifying local first responders not only protects them, but also facilitates a response in the event of an emergency at the facility.

Figure 2-4. Sample Letter to Local Fire Department.

Date

Chief, Local Fire Department Street City, State, Zip

This letter is to advise you of hazardous substances located at the (list name) U.S. Army Reserve facility, (provide address), managed by the 81st Regional Support Command (RSC). Our facility consists of an administrative building with a small motor pool/maintenance activity (provide appropriate description of facilities).

Enclosed are Hazardous Material and Hazardous Waste Inventory lists and a map of the facility that identifies the hazardous substances, quantities present, and storage locations. The inventories and map will be updated and resubmitted to you annually and/or if significant changes occur. This information is provided so that you are aware of the hazards in the event your department has to respond to an emergency here.

We would welcome your inspection of our facility for fire hazards of which we may not be aware. Please do not hesitate to call me at (phone number) should you have any questions.

Sincerely, Type your name Title

Enclosures

2.6 FORMS AND INSTRUCTIONS

This section contains the following form:

· Hazardous Material/Waste Inventory Form

HAZARDOUS…