Attachment_3_HW_Management_Plan.pdf

USAG Humphreys Hazardous Waste Management Plan

June 2017

Environmental Division, DPW USAG Humphreys

Updated by:

PUBLIC HEALTH COMMAND - PACIFIC

Diane Roberts

Physical Scientist (Environmental) Environmental Health Service Line, PHC-P

Reviewed by: _________________ Abdullatef I. Hamza Environmental Division, DPW

Approved by: ______________________________

LORI M. KIM

Chief, Environmental Division

Digitally signed by

KIM.LORI.M.1010877403

DN: c=US, o=U.S. Government, ou=DoD, ou=PKI, ou=USA, cn=KIM.LORI.M.1010877403 Date: 2017.07.14 15:21:17 +09'00'

USAG Camp Humphreys

June 2017

For Official Use Only

USAG Camp Humphreys Hazardous Waste Points of Contact

Name Responsibility Telephone Number 75 - 753-i For Official Use Only

Record of Review/Revision History

Date Review/Revision History Signature

March 2005 Hazardous Waste (HW ) was developed. Chin Song Kim

Sep 2010 was updated. Chin Song Kim June 2012 was updated. Chin Song Kim

July 2014 HM Management

Plan was removed from HM/HW Management Plan; HW Management Plan was updated.

O. Keith Smith

July 2017 was updated.

Hazardous Waste Management Plan

June 2017

June 2017 i For Official Use Only

TABLE OF CONTENTS

TABLE OF CONTENTS ................................................................................................... i ACRONYMS AND ABBREVIATIONS .............................................................................iv

1 INTRODUCTION...................................................................................................1-1

1.1 Background.....................................................................................................1-1

1.2 Objective .........................................................................................................1-1

1.2.1 Summary of Changes...............................................................................1-1

1.3 Applicable Requirements ................................................................................1-1

1.4 Implementation................................................................................................1-2

1.4.1 Revisions and Annual Review ..................................................................1-2

1.5 Scope of the Hazardous Waste Management Program..................................1-3

1.6 Locations and Mission.....................................................................................1-3

2 RESPONSIBILITIES .............................................................................................2-1

2.1 Hazardous Waste Management Organization and Authority ..........................2-1

2.2 Specific Responsibilities..................................................................................2-1

2.2.1 Commander, USAG Humphreys ..............................................................2-1

2.2.2 Directorate of Public Works Environmental Division.................................2-1

2.2.3 Defense Logistics Agency Disposition Services .......................................2-3

2.2.4 Director of Contracting..............................................................................2-3

2.2.5 Health, Dental, and Veterinary Clinics and Labs ......................................2-3

2.2.6 Waste Management Contractor................................................................2-4

2.2.7 Hazardous Waste Generating Activities and Units ...................................2-4

2.2.8 Environmental Officer/Alternate Environmental Officer.............................2-5

2.2.9 Fire Department........................................................................................2-6

2.2.10 Logistics Readiness Center (LRC) ........................................................2-7

2.2.11 EOC and EQCC ....................................................................................2-7

2.2.12 Command Safety Officer .......................................................................2-7

3 WASTE STREAM ACTIVITIES.............................................................................3-1

4 WASTE DETERMINATION...................................................................................4-1

4.1 Hazardous and Designated Waste Definitions................................................4-1

4.2 Waste Characterization Roles and Responsibilities ........................................4-1

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4.3 Waste Characterization Procedures................................................................4-1

4.4 Waste Characterization Frequency .................................................................4-2

4.5 Other Regulated Wastes.................................................................................4-5

4.5.1 Asbestos Containing Waste......................................................................4-5

4.5.2 Polychlorinated Biphenyls (PCBs) ............................................................4-5

4.5.3 Infectious Waste .......................................................................................4-6

5 HAZARDOUS WASTE ACCUMULATION ............................................................5-1

5.1 Hazardous Waste Accumulation Points ..........................................................5-1

5.2 Hazardous Waste Storage Areas....................................................................5-1

5.2.1 Design and Operation...............................................................................5-1

5.2.2 Signage and Security Requirements ........................................................5-2

5.2.3 Waste Analysis and Verification ...............................................................5-2

5.2.4 Hazardous Waste Log ..............................................................................5-3

5.2.5 Required Equipment.................................................................................5-3

5.2.6 Container Management ............................................................................5-4

5.2.7 Container Labeling and Marking...............................................................5-8

5.2.8 Inspections .............................................................................................5-11

5.3 Hazardous Waste Profile Sheets ..................................................................5-12

5.4 Hazardous Waste Turn-In to DLA .................................................................5-12

5.5 On-Post Transportation Requirements..........................................................5-14

5.6 Off-Post Transportation Requirements..........................................................5-14

5.6.1 Pre-transport requirements.....................................................................5-14

5.7 Recordkeeping..............................................................................................5-16

6 TRAINING.............................................................................................................6-1

6.1 Applicability .....................................................................................................6-1

6.2 Training Requirements....................................................................................6-1

6.2.1 DPW HW Manager and DPW Waste Management Contractors ..............6-2

6.2.2 Activity/Unit EO/AEO or HWSA Manager .................................................6-2

6.2.3 Activity/Unit HWAP Personnel ..................................................................6-2

6.2.4 On-Post Shippers/Transporters ................................................................6-2

6.2.5 Off-Post Shippers/Transporters ................................................................6-2

6.3 Refresher Training ..........................................................................................6-2

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6.4 Training Contacts ............................................................................................6-3

7 EMERGENCY RESPONSE AND CONTINGENCY PLANS .................................7-1

7.1 Applicability .....................................................................................................7-1

7.2 Emergency Contact Lists ................................................................................7-1

7.3 Emergency Response Procedures..................................................................7-1

7.3.1 Structural Controls....................................................................................7-1

7.3.2 Nonstructural Controls..............................................................................7-2

7.3.3 Initial Spill Response Procedures .............................................................7-2

7.4 Spill Procedures for HWAPs ...........................................................................7-3

7.5 Spill Reporting.................................................................................................7-3

LIST OF FIGURES AND TABLES

Figure 1-1. USAG Humphreys Installations, Republic of Korea ..................................1-4 Table 1-1 USAG Humphreys Installations/Sites...........................................................1-5 Figure 4-1. Hazardous Waste Identification Process ..................................................4-3 Figure 4-2. Designated Waste Identification Process..................................................4-4 Table 5-1. Examples of Incompatible Materials............................................................5-6 Figure 5.1. Hazardous Waste Label (USFK 42EK) .....................................................5-9 Figure 5.2. Hazard Warning Labels...........................................................................5-10 Figure 5-3. Non-Regulated Waste Label ...................................................................5-11 Figure 5-4. DD Form 1348-1A, Issue Release/Receipt Document............................5-13 Figure 7-1. Spill Report ...............................................................................................7-4

LIST OF APPENDIXES

APPENDIX A: Hazardous Waste Accumulation Points APPENDIX B: Hazardous Waste Storage Area Weekly Checklist APPENDIX C: US Forces Korea Regulation 201-1 Chapter 6 & Appendix B

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ACRONYMS AND ABBREVIATIONS

ACofS Assistant Chief of Staff AEO Alternate Environmental Officer APR Air-Purifying Respirator ASTM American Society for Testing and Materials °C Degrees Celsius CAS Chemical Abstract Service CDL Commercial Driver’s License CFR Code of Federal Regulations COC Chain-of-custody COLIWAS Composite liquid waste sampler DA Department of the Army DEROS Date Expected to Return to U.S.

DoD Department of Defense DCA Directorate Community Activities DLA Defense Logistics Agency DLA-DS Defense Logistics Agency Disposition Services DODAAC Department of Defense Activity Address Code DPW Directorate of Public Works DSO Directorate of Support Operations EPA U.S. Environmental Protection Agency EO Environmental Officer EOC Environmental Officer Council EQCC Environmental Quality Control Committee ETID Electronic Turn-In Document °F Degrees Fahrenheit FIC Facility Incident Commander (formerly Installation On-Scene

Coordinator) FRT Facility Response Team (formerly Installation Response Team) HAZMAT Hazardous Material HAZMART Hazardous Materials Pharmacy HAZCOM Hazard Communication HAZWOPER Hazardous Waste Operations and Emergency Response HM Hazardous Material HW Hazardous Waste HWAP Hazardous Waste Accumulation Point HWMP Hazardous Waste Management Plan HWPS Hazardous Waste Profile Sheet HWSA Hazardous Waste Storage Area HWST Hazardous Waste Storage Tank IATA International Airline Transport Association IAW In accordance with IMDG International Maritime Dangerous Goods

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ISCP Installation Spill Contingency Plan LRC Logistics Readiness Center KEGS Korean Environmental Governing Standards mg/l Milligrams per Liter NA Not Applicable NACE National Association of Corrosion Engineers ppm Parts per Million PCB polychlorinated biphenyl PHC-P Public Health Command Pacific POC point-of-contact POL Petroleum, Oils, and Lubricants POV Privately Owned Vehicle PPE Personal Protective Equipment RCRA Resource Conservation and Recovery Act ROK Republic of Korea SA Support Activity SCIW Specially Controlled Industrial Waste SDS Safety Data Sheet SOP Standard Operating Procedure SPRP Spill Prevention and Response Plan TSDF Transport Storage or Disposal Facility UIC Unit Identification Code UN United Nations USFK U.S. Forces Korea WAP Waste Analysis Plan

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1 INTRODUCTION

1.1 Background

This Hazardous Waste Management Plan (HWMP) provides guidance to personnel who generate, treat, store, or dispose of hazardous waste at the USAG Camp Humphreys in the Republic of Korea (ROK). This plan applies to all facilities supported by USAG Humphreys and supersedes the “Hazardous Materials and Waste Management Plan for USAG Camp Humphreys, Republic of Korea” dated July 2014. This update was prepared by the U.S. Army Public Health Command Pacific, Environmental Health Engineering Division.

1.2 Objective

The U.S. Army is committed to proper management of hazardous wastes generated on its installations. The objective of this HWMP is to provide personnel who generate or manage hazardous waste with the essential tools for effective management.

1.2.1 Summary of Changes

This HWMP has been revised to reflect current operational conditions requiring compliance with the Korea Final Governing Standards. References and discussions based on U.S. regulatory requirements for hazardous waste management and transportation that do not apply to overseas installation and other extraneous information have been removed.

1.3 Applicable Requirements

Environmental management criteria for U. S. Forces Korea (USFK) installations in the ROK are provided in the USFK Regulation 201-1, Environmental Governing Standards (KEGS). The KEGS are the Final Governing Standards issued under DoD Instruction (DoDI) 4715.5, “Management of Environmental Compliance at Overseas Installations.”

Management criteria for hazardous and designated wastes at USFK installations are contained in Chapter 6 and Appendix B of the KEGS. The KEGS also contain the definitions for terminology used throughout this document. The complete text and tables of KEGS Chapter 6 and Appendix B has been provided in Appendix A of this HWMP for reference.

The hazardous waste management criteria in the KEGS are based substantially on U.S.

Environmental Protection Agency (EPA) regulations, promulgated in Title 40 of the Code of Federal Regulations (40 CFR). In addition, the KEGS criteria also provide requirements for the management of designated wastes, which are analogous to hazardous waste under ROK law.

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The definition and listing of specific designated wastes are contained in KEGS Appendix B. Designated wastes are also broadly defined as wastes that can pose a risk to the environment or wastes that can do harm to human health. Under this broad definition, hazardous wastes are considered designated waste under ROK law, and their management, transportation and disposal must conform to ROK requirements once the wastes are transported off of USFK installations.

29 CFR Part 1910.120, Hazardous Waste Operations and Emergency Response

Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods, Update IV (SW-846)

Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Waste: A Guidance Manual, OSWER 9938.4-03

A Method for Determining the Compatibility of Hazardous Wastes, EPA/600/2- 80-076

A Compendium of Superfund Field Operations Methods, EPA/540/P-87/001

Department of Defense (DoD) 4160.21-M, Defense Materiel Disposition Manual

DoD 4000.25-1-M, Military Standard Requisitioning and Issue Procedures

DoD Instruction 6050.05 DoD Hazardous Communication Program

1.4 Implementation

Implementation of the comprehensive hazardous waste management program requires maximum cooperation of all United States Forces Korea (USFK) activities at the USAG Humphreys. It is the responsibility of the USAG Humphreys Commander to ensure compliance with hazardous waste management requirements for the installation.

Individual organizations at the USAG Humphreys including tenants, contractors, and any activity generating, accumulating, monitoring, disposing, or responding to hazardous waste incidents on base, are accountable for conducting their activities in accordance with this plan.

1.4.1 Revisions and Annual Review

This HWMP will be reviewed annually. The annual review is a formal process to verify that information and procedures in the plan are up to date. The review will include ensuring contact information, hazardous waste generating activities, hazardous waste accumulation points (HWAP), hazardous waste storage areas (HWSA), and regulatory

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This HWMP will be revised whenever there are changes to the organization, mission, or operations at the USAG Humphreys that materially alters the type or quantity of hazardous wastes generated. This plan will also be revised if there is a need to comply with new regulatory requirements or when responsibilities or contact information undergo significant change. All revisions to this plan will be documented in the Record of Changes. Minor revisions can be made by inserting updated page(s) into the document. Major changes can be incorporated when the plan is next updated.

1.5 Scope of the Hazardous Waste Management Program

This plan addresses key elements of the hazardous waste management program required by KEGS, which is applicable to all USFK installations in the ROK. The hazardous management program must comply with KEGS and Army requirements applicable to overseas installations. The proper management of hazardous waste from the point of generation through disposal is of upmost importance, both in terms of protecting human health and the environment, and to demonstrate sound environmental stewardship to the host nation to ensure continued access to the necessary facilities and installations for the USAG Humphreys to accomplish its missions.

1.6 Locations and Mission

USAG Humphreys covers 4.5 million square meters in the valley of the Asan, and is the largest U.S. Army installation in terms of area, number of units and personnel assigned.

The installation has undergone rapid growth in support of planned future movement of units from Yongsan Garrison in Seoul and other units from Area I (south of the Demilitarized Zone but north of Seoul). USAG Humphreys hosts a multitude of various units, which include: flying units, military intelligence, medical units, and motor pools.

There are also motor pools associated with military units and the maintenance of tactical vehicles, while non-tactical vehicles are maintained at a Transportation Motor Pool complex. JP-8 jet fuel and MOGAS are piped into the installation to several large underground storage tanks at the bulk fuel storage facility.

The soldiers and civilians of USAG Humphreys provide direct support to residents and tenant commands within USAG Humphreys.

The headquarters of USAG Humphreys is located at Camp Humphreys and offers support for 10 other Army sites within Area III illustrated on a map in Figure 1-1 and listed in Table 1-1.

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Figure 1-1. USAG Humphreys Installations, Republic of Korea

Area II

Area III

Yongsan

Area IV

Area I

Camp Humphreys

Pyongtaek CPX

Site Beason

Wonju LSA

Bayonne

High Point

Camp Ames

Site Richmond

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Table 1-1 USAG Humphreys Installations/Sites Installation Name City Site ID Site Code

Beason Yongpyong 3555 3555 Camp Ames Taejon 4228 4228 Bayonne Signal Site Yongin 187987 187987 High Point Unknown 3590 3590 Pyongtaek Cpx Area Pyong Taek 6911 6911 Richmond Taejon 6994 6994 Camp Humphreys Pyong Taek 4261 4261 Pyongtaek RTO Site Pyong Taek 188185 188185 b

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2 RESPONSIBILITIES

2.1 Hazardous Waste Management Organization and Authority

Successful implementation of the HWMP and proper hazardous waste management require proper organization and cooperation among all activities and at all levels of command as well as an understanding of the USAG Humphreys hazardous waste management authority. Key organizations and individuals include the Commander of USAG Humphreys, DPW Environmental Office, HAZMART, Defense Logistics Agency- Disposition Services (DLA-DS), and hazardous waste generators.

2.2 Specific Responsibilities

2.2.1 Commander, USAG Humphreys

The USAG Commander is responsible for management of hazardous waste and for ensuring compliance with all applicable requirements by tenant and support activities.

The Commander must ensure that all hazardous waste generators and facility operators comply with regulatory requirements and that DPW Environmental Office has the support necessary to implement hazardous waste management.

2.2.2 Directorate of Public Works Environmental Division

Support all of the Area III community by maintaining an environmental program that sustains the Army mission and secures the future by implementing the following responsibilities:

Maintains, implements, updates, and distributes the HWMP and supporting documents to all facility personnel (including tenants) who generate, transport, treat, store, or dispose of hazardous waste

Develops and maintains a master listing of all storage locations and inventories of all Hazardous Material(HM)/Hazardous Waste(HW) and provides a copy to the Installation Fire Department

Acts as coordinator and liaison with disposal facilities (DLA-DS and contractors)

Provides technical assistance and guidance to hazardous waste generators to include:

- Developing, implementing and providing standard operating procedures (SOP) to properly manage hazardous waste in their operations

- Performing annual waste characterizations for generating units/activities

- Assist generators in disposing of hazardous waste

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Signs waste manifests

Inspects HW operations and initiates corrective measures including recommending equipment for HW handling and storage

Provide or Environmental Officer and HM/HW handler training

Maintains audit trail from point of HW generation to disposal

Serves as a member of the EQCC(Conduct/Host Environmental Officer Council (EOC) and EQCC meetings

Files generator exemption reports

Coordinates availability of spill response and prevention material and emergency Supplies

Acts as a liaison with the USFK, DLA-DS, and other Federal and ROK agencies in matters relating to HW

Ensures that information pertaining to new HW policies and procedures are communicated to the activity/unit EO/AEO

Conducts compliance inspections on USAG Humphreys

Notifies generating activities/units of deficiencies identified during site inspections

Coordinates the collection and transportation activities required to dispose of HW or HM

Develops a program and budget resources to effectively manage hazardous waste

Advises the Commander of USAG Humphreys on all aspect of hazardous waste management

Uses HM and HW inventories to monitor implementation of a hazardous waste minimization program; assists generators in implementation of the hazardous waste minimization program; and initiates processes to replace all HMs with less hazardous or non-hazardous materials

Uploads HW Inventory Log to the DPW Share point for emergency personnel monthly

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2.2.3 Defense Logistics Agency Disposition Services

Operates under guidelines promulgated by the Defense Logistics Agency (DLA) and DoD

Determines marketability of all DoD owned HM/HW for proper sale, reuse, or disposal

Contracts for HW disposal in accordance with DoD 4160.21-M, Chapter XI and DLAM 6050.1 and complies with all Federal, USFK, DA, and the KEGS

Provides contract coordination and support

Accept responsibility for disposal of properly hazardous waste generated in USAG Humphreys

Provides and maintains a proper hazardous waste storage facility that conforms to applicable regulatory requirements

Maintains transportation and disposal records for all manifested hazardous waste

Provides necessary support to DPW Environmental Office, particularly concerning the annual hazardous waste inventory

2.2.4 Director of Contracting

Serves as a member of the EQCC

Ensures that contracts for outside services include provisions for compliance with the KEGS and this HWMP

Ensures contractive support to obtain equipment or services required by the

HWMP

2.2.5 Health, Dental, and Veterinary Clinics and Labs

Responsible for the disposal of regulated medical waste in accordance with (IAW) Federal, USFK, DA, MEDCOM and KEGS

Complies with HW generator requirements of this HWMP and the KEGS

Communicates with the MEDDAC-Korea Environmental Science Engineering Officer for assistance with waste characterization

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Utilizes MEDCOM Environmental Program Requirement dollars for waste disposal

2.2.6 Waste Management Contractor

Completes HW profile sheets for all characterized waste streams

Accepts accountability and/or custody of waste containers that require disposal

Issues instructions to generating activities/units regarding waste turn-in procedures

Delivers labeled/bar coded waste accumulation containers to generating activities/units

Provides a container log for each waste container issued to the generating activity/unit

Accepts HWs from activities/units and stores them at the Installation HW storage area (HWSA) for processing and disposal

Packages, marks, and labels HW for off post transportation IAW DoD, Department of Transportation (DOT), and USFK regulations

Prepares manifests for signature

Generates HW log report to DPW Environmental every month for emergency personnel

Conducts weekly inspection log to the HWSA and maintains inspection records for minimum of three years

Keeps waste analysis/characterization records

2.2.7 Hazardous Waste Generating Activities and Units

Hazardous waste generators include US Army organizations, tenants and contractors.

During the course of normal operations, hazardous waste generators produce or identify wastes determined to be hazardous according to the KEGS. Generator responsibilities, which may be specifically applicable to HWAP environmental officer, and HWSA managers, include the following:

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Ensure HW is managed IAW with this Plan and not released into the environment

Report instances of non-compliance to DPW Environmental Division within 24-hours (immediately)

Appoint and train activity/unit personnel to serve as EO/AEO to ensure operational compliance and coordination with the DPW staff

Ensure that an adequate number of EO/AEO are available at all times (holidays/leave/absences)

Support updating of the hazardous waste inventory by notifying DPW Environmental Office when any changes in operations occur that affect the quantity or type of waste generated

Ensure that HM/HW storage practices minimize the potential for spills

Ensure spill response and prevention materials are available

Report spills or releases of HMs, and/or HWs to the Installation Fire Department and Environmental Division

Be familiar with the ISCP and SPRP, and respond properly to emergencies;

Place HW in suitable containers that have been properly identified

2.2.8 Environmental Officer/Alternate Environmental Officer

Coordinate HW delivery with the DPW waste management contractor

Ensure that HM & HW storage areas are maintained in accordance with this Plan

Conduct and document monthly inspections IAW this HWMP and associated Standard Operating Procedures (SOPs)

Ensure all personnel involved with handling and storage of HM and HW are provided with proper training (see Section 6)

Determine whether a new process or activity will generate waste and determine whether waste is hazardous, and properly document this determination Notify DPW Environmental of new waste generation or changes in waste generating processes

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Attend all training and meetings scheduled by DPW Environmental

Ensure SDSs are available for all HMs

Respond to and report all spills and HW accidents/incidents

Maintain HW records

Follow the hazardous waste minimization plan implemented by HAZMART; take necessary steps to minimize the amount of hazardous waste generated, and segregate hazardous and nonhazardous wastes.

Develop SOPs for HM/ HW handling and a training program for all personnel handling HM/ HW

Stock adequate supplies of hazardous waste packaging, labels, spill response equipment, and personal protective equipment (PPE)

2.2.9 Fire Department

Fire department has the following hazardous waste responsibilities:

Ensures compliance with fire protection regulations

Inspects hazardous waste generating activities, HWAP and HWSA during fire safety inspections

Equips the installation HAZMAT Incident Response Team

Acts as the Incident Commander during HAZMAT Incident Responses

Ensures training is provided for firefighter personnel to maintain proficiency in responding to HM/HW accidents/incidents

Responds to HM/HW incidents

Assists in training activity/unit personnel as requested by DPW

Maintains technical library (SDSs, chemical hazards, etc.)

Maintains installation wide HM/HW inventory, as provided by DPW

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2.2.10 Logistics Readiness Center (LRC)

Ensures that SDSs are provided with HM shipments/distributions to activities/units

Monitors installation wide use of HMs

Manages the Hazardous Materials Control Center (HAZMART)

Manages the Hazardous Materials Management Program (HMMP)

2.2.11 EOC and EQCC

Identifies required resources and provides program oversight

Establishes evaluation criteria and continuously monitors program success

Reviews and approves mission processes and the use of associated HMs for those processes (called authorized use/user lists or AUL)

Minimum committee membership will include:

- DPW

- HAZMART

- Command Safety Office

- Directorate of Public Works

- HM Control Center

- Tenant Activities/Units

The HMMP Committee agenda will be addressed during EQCC Meetings because the same members attend both committees.

2.2.12 Command Safety Officer

Serves as a member of the EQCC

Ensures Occupational Safety and Health Act (OSHA) requirements are met for personnel involved in the implementation of this Plan

Assists DPW in the implementation of this Plan

Incorporates this plan into the Command Safety Program to schedule routine inspections of HM and HW storage and handling facilities

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Provides DPW with any findings or deficiencies found during safety inspections

Ensures SDSs are available

Ensures personal protective equipment (PPE) is available for soldiers and civilians

Ensures that proper measures like emergency showers and eye washers are available for routine treatment, control, and emergency clean-up

Ensures approval of new HMs [Authorized User List (AUL)]

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3 WASTE STREAM ACTIVITIES

The types of hazardous wastes generated at the USAG Humphreys are listed by HWAP and HWSA in Appendix A.

Hazardous wastes may only be stored in approved HWAP and HWSA. An HWAP may be used to accumulate up to 208 liters (55 gallons) of hazardous waste, or 1 liter (1 quart) of acute hazardous waste from each waste stream. When these limits have been reached, arrangements must be made to move the waste to an HWSA or shipped off the installation for treatment or disposal. HWSA should not be used to store wastes for longer than one year; storage should be limited to 90 days if possible.

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4 WASTE DETERMINATION

USFK installations and activities that generate wastes that might contain hazardous or toxic chemicals are required by the KEGS to prepare and implement a waste analysis plan (WAP) to ensure that wastes are properly identified and managed accordingly. This plan is outlined in a document separate from this HWMP and maintained by the USAG DPW Environmental Division.

4.1 Hazardous and Designated Waste Definitions

The KEGS Chapter 6 defines a hazardous waste as a solid, liquid or gas that exhibits a characteristic of a hazardous waste as defined in the KEGS Appendix B-1 or is a listed hazardous waste in the KEGS Tables B-3 and B-4. USFK hazardous waste destined for disposal at a ROK disposal facility will be identified as designated waste upon leaving the installation and includes wastes as defined under Chapter 6.l(1)(a) and (b).

The KEGS Chapter 6 and Appendix B are provided in Appendix C of this plan.

4.2 Waste Characterization Roles and Responsibilities

The following roles and responsibilities apply to waste characterization:

Activity/unit EOs/AEOs are responsible for notifying DPW of all wastes generated by new waste generating processes and/or changes to existing waste generating processes in their activities/units and for maintaining DRMS Form 1930, Hazardous Waste Profile Sheets (HWPS) for all waste streams for a period of four years.

DPW personnel are responsible for ensuring all wastes generated on USAG Humphreys installations are properly characterized to determine if they are HW, designated wastes, used POL, waste antifreeze, or non-hazardous wastes.

Generating activities will provide verification of incoming waste by completing and maintaining a DRMS Form 1930, Hazardous Waste Profile Sheet for each characterized HW, used POL, waste antifreeze, or non-hazardous waste stream.

Note: A HWPS is not required for turn-in of expired, unused, unopened HMs; the required supporting documentation for a HM is an SDS.

4.3 Waste Characterization Procedures

Each waste stream generated must undergo waste characterization to determine if it requires HW or designated waste disposal/treatment. The HWSA manager, with the DPW Environmental Division will develop and maintain a Waste Analysis Plan that will

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4-2 For Official Use Only identify the procedures for characterization of hazardous/designated waste generated on all installations supported by USAG Humphreys. The WAP will include procedures for characterization and verification testing. The plan should include: parameters for testing and rationale for choosing them, frequency of analysis, test methods, and sampling methods. The WAP will use Korean testing procedures for hazardous/designated waste to be treated/disposed of off the installation. Waste characterizations may be based on generator knowledge or SDS information. If it is not possible to make a waste characterization using generator knowledge or SDS information, chemical analyses will be performed IAW the WAP.

The hazardous and designated waste identification processes are illustrated on Figures 4-1 and 4-2, respectively.

For waste characterization assistance, contact the DPW Environmental Division Chief, the DPW HW Manager, or the DPW waste management contractor:

HW Program Manager DPW Environmental Division Phone number: 753- 3607

DPW Environmental Chief DPW Environmental Division Phone number: 753-7964

HAZMART DPW Waste Management Contractor Phone number: 753-7710/7754

Note that there are several chemicals that appear as both hazardous waste and designated waste. Wastes that contain these chemicals are assigned as hazardous waste, designated waste, or both, depending on the concentration and the hazardous and designated waste regulatory levels.

4.4 Waste Characterization Frequency

The DPW HW Manager and the HWSA Manager will evaluate and update waste characterizations annually.

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Figure 4-1. Hazardous Waste Identification Process

Is the material solid waste under the KEGS?

Does the waste exhibit any of the characterization of hazardous waste in the KEGS? Appendix

Is the material domestic sewage, household waste or infectious waste?

Does the waste meet any of the listing descriptions in Appendix B, Tables B-3 or B-4 of the KEGS or is the waste mixed with a listed HW or is the waste derived from treatment, storage or disposal of a listed HW?

Does the waste exhibit any of the characterizations of hazardous waste in KEGS

Appendix B Section B-1?

Yes

Yes

Yes

No

Yes

No

No

No

No

Not a listed hazardous waste

Not a hazardous waste

Listed Hazardous

Waste Yes

Note – You must determine if the waste is a designated waste

Not a hazardous wasteCharacteristic and Listed Hazardous

Waste

Listed Hazardous

Waste

Characteristic Hazardous

Waste

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Figure 4-2. Designated Waste Identification Process

Is the waste:

Waste synthetic polymer consisting of waste synthetic resin generated from the manufacture process of synthetic resin, or waste synthetic rubber generated from the manufacture of synthetic rubber, or pesticide manufacturing process waste?

A corrosive waste (pH <2 or >12.5)?

PCB Containing Waste (liquid waste with a total PCB content of >2mg/L or waste other than liquid with a PCB content of 0.003mg/L in the extraction liquid? (See 4.5.2)

One of the following types of waste that contain a substance listed in the KEGS Appendix B, section B-3k above the listed limit?

Slag Particulate matter from air pollution prevention facility Waste casting sand or waste sand from sand-blasting Waste fire resistant material or pieces of pottery before glaze coat Incineration ash Waste treated by stabilization or solidification Waste catalyst

A hazardous material listed in the KEGS Chapter 5, Table 5-5 or 5-6 which becomes a waste?

Waste oil with >5% oil (excluding PCB containing waste or waste edible oil)?

Infectious waste as defined in the KEGS Chapter 8 or MEDCOM Regulation 40.35? (see Section 4.5.3)

Waste asbestos as outlined in the KEGS Appendix B, section B-3g (see Section 4.5.1

Not a designated waste

This waste Is a designated waste

Waste organic solvent listed in the KEGS Appendix B, section B-3d?

Waste paint or waste lacquer as outlined in the KEGS Appendix B, section B-3e?

No

No

No

No

No

No

No

No

No

No

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

June 2017

4-5 For Official Use Only

4.5 Other Regulated Wastes

4.5.1 Asbestos Containing Waste

Asbestos containing waste must be managed properly because of the known hazards associated with the release of asbestos fibers into the air. Asbestos is not a characteristic or listed hazardous waste; but certain types of asbestos containing waste are “waste asbestos” under designated waste definition. Asbestos containing building material removed as part of an abatement project would be waste asbestos and a designated waste.

The only asbestos containing waste streams that may be generated on a regular basis from activities supported by USAG Humphreys are brake shoes, clutch discs, and gasket materials. These items should be assumed to contain asbestos unless there is proof they do not. An SDS, certification in writing from the manufacturer or analytical testing are acceptable as proof.

Asbestos waste must be double bagged using plastic bags or they may be placed in a sealed, leak proof, durable container. Label the plastic bags/waste container with

“DANGER – CONTAINS ASBESTOS FIBERS – AVOID CREATING DUST – CANCER

AND LUNG DISEASE HAZARD” in English and Korean. Turn-in to the DPW waste management contractor for disposal in an approved facility.

4.5.2 Polychlorinated Biphenyls (PCBs)

Polychlorinated biphenyls must be handled with extreme care to prevent entry into the environment from spills, leakage, vaporization, and/or disposal. Because PCB treatment and disposal is very specific and stringently regulated, all PCB containing wastes must be collected and turned in through the DLA-DS for treatment/disposal. Testing (characterization), packaging, labeling, and transport must meet DLA-DS requirements.

Items containing greater than 50 parts per million PCBs must be labeled with a PCB label.

Contact the DPW Environmental Division and/or the Gimcheon DLA-DS for assistance with possible PCB containing waste oil, ballasts, capacitors, and transformers.

DPW HW Manager: 753-3607

DLA-DS Environmental Branch, Gimcheon: 763-0617

June 2017

4-6 For Official Use Only

4.5.3 Infectious Waste

Infectious waste disposal is contracted by the 121st Combat Support Hospital/Brian Algood Army Community Hospital Medical Logistics Environmental Services Branch.

USAG Humphreys is not responsible for infectious waste disposal.

Hazardous waste generated by medical activities will be done IAW this management plan.

June 2017

5-1 For Official Use Only

5 HAZARDOUS WASTE ACCUMULATION

Hazardous and designated wastes generated by activities are initially stored in HWAPS.

The wastes are transferred to the HWSA when the storage limits of the HWAP are reached. Hazardous and designated wastes are transported from the HWSA via contract by DLA for ultimate treatment and disposal.

5.1 Hazardous Waste Accumulation Points

An HWAP is a site where HWs, Used POL, Used Antifreeze, Used Batteries and non-regulated waste are accumulated until removed to a HWSA or shipped for treatment or disposal. The HWAP must be at or near the point of generation and under the control of the operator. HWAP is managed by the unit Environmental Officer (EO) IAW the EGS requirements. Up to 208 liters (55 gallons) of hazardous waste or 0.95 liter (1 quart) of acute hazardous waste from each waste stream may be accumulated at the HWAP.

When the HWAP storage limits have been reached, arrangement must be made to transfer wastes to the HWSA within 5 working days. The USAG Humphreys HWAP SOP provides guidance for initiating HW turn in to the HWSA. Wastes intended to be recycled or used for energy recovery (for example, used oil or antifreeze) are exempt from the 208 liter (55 gallons)/0.95 liter (one quart) volume accumulation limits, but must be transported off-site to a final destination facility within one year. Used POL will be picked up by the POL contractors. In addition, all the requirements presented in the EGS regarding “Use and Management of Containers”, “Record-Keeping, and “Personnel Training” will apply.

Management requirements are also provided in the USAG Humphreys HWAP Standard Operating Procedures (SOP). Units are required to ensure they are using the most current SOP.

A list of HWAPS at Camp Humphreys is provided in Appendix A.

5.2 Hazardous Waste Storage Areas

USAG Humphreys has one HWSA located at Camp Humphreys at Building# 1019.

5.2.1 Design and Operation

The HWSA is designed, constructed, maintained, and operated to minimize the possibility of a fire, explosion, or any unplanned release of hazardous waste or hazardous waste constituents to air, soil, groundwater, or surface water that could threaten human health or the environment. Hazardous waste should not be stored longer than one year in a HWSA.

June 2017

5-2 For Official Use Only

The aisle space between hazardous waste containers will allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of the facility during an emergency. Containers must not obstruct an exit.

All personnel involved in the operation must have immediate access to an internal alarm or communication device such as cellular telephone or two way radio, to summon assistance in the event of an emergency in compliance with their respective health and safety plan for such activity.

HWSA will have a secondary containment with sufficient capacity to contain ten percent of the volume of all containers or the entire volume of the largest container, whichever is greater.

Rainwater or condensation captured in secondary containment systems should be inspected and/or tested prior to release. The inspection or testing must be reasonably capable of detecting contamination by the hazardous waste in the containers. Water that accumulates in containment systems shall be treated as hazardous waste until determine otherwise.

5.2.2 Signage and Security Requirements

The HWSA must be operated and secured in a manner that prevents unknowing entry and minimizes the possibility for unauthorized entry. Camp Humphreys HWSA is in a fenced area with controlled access. All locks associated with access to the HWSA are kept locked except when waste is being transferred or during inspections.

Signs with the legends "Danger Unauthorized Personnel Keep Out," and “No Smoking” must be posted at each entrance to the hazardous waste storage area, and at other locations, in sufficient numbers to be seen from any approach to the HWSA. The legend must be written in English and Korean, and must be legible from a distance of at least 25 feet. Existing signs with a legend other than "Danger Unauthorized Personnel Keep Out," may be used if the legend on the sign is written in both English and Korean and indicates that only authorized personnel are allowed to enter the hazardous waste storage area, and that entry to it can be dangerous.

5.2.3 Waste Analysis and Verification

All hazardous and designated waste placed into storage at the HWSA must be inspected to ensure the waste matches the description provided by the generator. Each waste stream shall also have a HWPS. If there is no existing HWPS, one shall be prepared with waste stream characterization completed in accordance with the WAP.

June 2017

5-3 For Official Use Only

5.2.4 Hazardous Waste Log

Every container placed into storage must be recorded on a Hazardous Waste Inventory (Log). The log will be kept current and provide the following information:

Name and address of the generator (installation and unit)

Description and hazard class of the hazardous waste

Number and type of container

Quantity of hazardous waste (weight or volume)

Date placed into storage at the HWSA

Storage location

Waste disposition information including dates received, sealed, and transported to DLA-DS, and the name of the transporter company

The Hazardous Waste Log will be available to emergency response personnel in the event of a fire or spill. It is uploaded month to the DPW SharePoint.

5.2.5 Required Equipment

Portable fire extinguishers and other fire control equipment appropriate for the material in storage. Water at adequate volume and pressure to supply hose streams, foam producing equipment, automatic sprinklers or water spray systems (except at facilities where wastes incompatible with water are stored).

Spill control, decontamination equipment, and readily available personal protective equipment appropriate to the materials stored, as well as eyewash and shower facilities.

An internal communications or alarm system capable of providing immediate emergency instruction (voice or signal) to HWSA personnel. A device capable of summoning emergency assistance from installation security, fire departments or emergency response teams, such as an intrinsically safe telephone (immediately available at the scene of operations) or a hand-held two-way radio.

These requirements will be inspected weekly using the HWSA Weekly Inspection Form provided in Appendix B.

June 2017

5-4 For Official Use Only

5.2.6 Container Management

To protect human health and the environment, containers that meet performance oriented packaging standards based on the United Nations Recommendation on the Transport of Dangerous Goods should be used (U.S. Department of Transportation specifications are based on the United Nations standards). The following requirements shall apply during handling and storing of hazardous and designated waste containers:

Containers holding hazardous waste will be in good condition and free of rust, bulges, or severe structural defects

Containers will be stored in such a manner so that labels are easily visible

Containers should not have to be moved in order to read labels

Different hazardous waste streams must be accumulated in separate containers.

Non- hazardous waste must not be mixed with hazardous or designated wastes

Waste containers that are incompatible with other wastes containers will not be stored next to each other without a means of segregation and/or secondary containment

A container holding a hazardous a waste must always be closed during storage, except when it is necessary to add or remove waste

A container holding hazardous waste must not be opened, handled, or stored in a manner that may rupture the container or cause it to leak

A funnel will be used to fill closed head containers (If the funnel used is not the type with a locking top, the funnel should be removed and the container closed after filling)

Containers on pallets must be secured to the pallet prior to moving

Handle drums and containers with equipment designed for that purpose, such as drum carts or cradles and forklift drum carrier attachment of sling

Containers holding liquid wastes should be stored away from floor drains that lead to storm drains, sewers, and water sources

Containers must be inspected weekly for signs of leakage, deterioration, and the integrity of the containment system

June 2017

5-5 For Official Use Only

Leaking containers must be over packed, or the waste must transferred to a serviceable container immediately

Containers must not block entrances/exits in the event of an emergency

Allow at least one meter (three feet) of aisle space for emergency response procedures and inspections

Containers for liquid wastes should be filled to no more than 80 percent capacity

Containers must not be exposed to snow, ice and/or rain

Containers will not be stacked

Special Requirements for Ignitable, Reactive, or Incompatible Waste

Storage areas for containers holding ignitable or reactive waste must be located at least 15 meters (50 feet) inside the installation's boundary. "No Smoking" signs or appropriate icon must be conspicuously placed wherever there is a hazard from ignitable or reactive waste. The "No Smoking" legend must be written in English and Korean. Water reactive waste cannot be stored in the same area as flammable and combustible liquid.

Containers of ignitable liquids must be

Separated and protected from ignition sources and conditions that would cause reaction, including but not limited to: open flames, cutting and welding,…