HAZARDOUS WASTE MANAGEMENT PLAN UNITED ... Rucker...Hazardous Waste Program Manager 334-255-1024...

FINAL

HAZARDOUS WASTE MANAGEMENT PLAN

UNITED STATES ARMY AVIATION CENTER OF EXCELLENCE

FORT RUCKER, ALABAMA

Prepared for: U.S. Army Corps of Engineers

Mobile District Mobile, Alabama

Prepared by Trinity Analysis & Development Corp.

1002 North Eglin Parkway Shalimar, FL 32579

(850) 613-6800

September 2016

This page left intentionally blank.

TABLE OF CONTENTS

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TABLE OF CONTENTS Contact List .................................................................................................................. xi Section 1 Introduction ............................................................................................. 1-1

1.1 Purpose and Objective .............................................................................. 1-1

1.2 Applicability ............................................................................................... 1-1

1.3 Implementation ......................................................................................... 1-2

1.4 Fort Rucker Environmental Management System ..................................... 1-2

1.4.1 Plan Review ................................................................................... 1-2

1.4.2 Revision Log .................................................................................. 1-3

Section 2 Installation and Regulatory Overview ................................................... 2-1

2.1 General ..................................................................................................... 2-1

2.2 Regulatory Authority ................................................................................. 2-7

2.2.1 Federal Regulations ....................................................................... 2-7

2.2.2 State Regulations .......................................................................... 2-7

2.2.3 Army Regulations .......................................................................... 2-8

2.2.4 Fort Rucker Policies ....................................................................... 2-9

2.3 RCRA Generator Status ......................................................................... 2-10

2.4 EPA Identification (ID) Number ............................................................... 2-12

2.5 Hazardous Waste Accumulation Sites (HWAS) ...................................... 2-12

2.6 General Hazardous Waste Training Requirements ................................. 2-13

Section 3 Responsibilities ...................................................................................... 3-1

3.1 General ..................................................................................................... 3-1

3.2 Garrison Commander ............................................................................... 3-1

3.3 Environmental Quality Control Committee (EQCC) .................................. 3-2

3.4 Commanders, Directors, and Supervisors (Military, Civilian, and

Contractors) ....................................................................................................... 3-2

3.5 Hazardous Waste Satellite Accumulation Point (HWSAP) Managers ....... 3-4

3.6 90-HWAS Managers ................................................................................. 3-6

3.7 Personnel Working With Hazardous Wastes ............................................ 3-8

3.8 EO and EPOC ........................................................................................... 3-8

3.9 Director of Public Works ........................................................................... 3-9

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3.10 DPW-ENRD ........................................................................................... 3-9

3.11 Defense Logistics Agency Disposition Services (DLADS) Eglin .......... 3-11

3.12 Public Affairs Office (PAO) .................................................................. 3-11

3.13 Logistics Readiness Center (LRC) ...................................................... 3-12

3.14 Civilian Personnel Advisory Center (CPAC) ........................................ 3-12

Section 4 Hazardous Waste Identification and Classification ............................. 4-1

4.1 General ..................................................................................................... 4-1

4.2 Exemptions from Hazardous Waste Definition .......................................... 4-1

4.3 Listed Wastes ........................................................................................... 4-2

4.4 Characteristic Wastes ............................................................................... 4-3

4.5 Fort Rucker Waste Identification Requirements ........................................ 4-4

Section 5 Hazardous Waste Satellite Accumulation Points ................................ 5-1

5.1 General ..................................................................................................... 5-1

5.2 HWSAP Managers .................................................................................... 5-1

5.3 Waste Accumulation Quantities ................................................................ 5-2

5.4 Container Management Requirements ..................................................... 5-3

5.4.1 Compatibility .................................................................................. 5-3

5.4.2 General Requirements ................................................................... 5-3

5.4.3 Liquid Waste Container Requirements .......................................... 5-4

5.4.4 Labels and Signs ........................................................................... 5-4

5.4.5 Interim Container Management ..................................................... 5-4

5.5 Security ..................................................................................................... 5-4

5.6 Spill Prevention and Response ................................................................. 5-5

5.7 Inspections ................................................................................................ 5-6

5.8 Training ..................................................................................................... 5-7

5.9 Recordkeeping .......................................................................................... 5-8

5.9.1 Records that must be kept in the HWSAP ..................................... 5-8

5.9.2 Records that may be kept in a separate work area ........................ 5-8

Section 6 Hazardous Waste Accumulation Sites .................................................. 6-1

6.1 Hazardous Waste Accumulation Sites ...................................................... 6-1

6.2 Waste Accumulation ................................................................................. 6-1

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6.3 Signage ..................................................................................................... 6-2

6.4 Facility Specifications ................................................................................ 6-2

6.5 Container Management Requirements ..................................................... 6-3

6.5.1 Container Stacking ........................................................................ 6-3

6.5.2 Container Specifications ................................................................ 6-3

6.5.3 Waste and Container Compatibility ................................................ 6-4

6.5.4 Damaged Containers ..................................................................... 6-5

6.5.5 Container Labeling ......................................................................... 6-5

6.6 Security ..................................................................................................... 6-6

6.7 Spill Prevention and Response ................................................................. 6-6

6.8 Inspections ................................................................................................ 6-7

6.9 Training ..................................................................................................... 6-7

6.10 Recordkeeping ...................................................................................... 6-8

6.10.1 Records that must be kept in the 90-HWAS ................................ 6-8

6.10.2 Records that may be kept in a separate work area ...................... 6-9

Section 7 Hazardous Waste Disposal Procedures ............................................... 7-1

7.1 General ..................................................................................................... 7-1

7.2 Hazardous Material Reuse Evaluation ...................................................... 7-1

7.3 Preparation for Disposal and Packaging ................................................... 7-1

7.4 Hazardous Waste Turn In Procedures ...................................................... 7-2

7.5 Waste Profiles ........................................................................................... 7-2

7.6 Hazardous Waste Marking and Labeling Requirements ........................... 7-3

7.6.1 General Requirements ................................................................... 7-3

7.6.2 Marking .......................................................................................... 7-4

7.6.3 Labeling ......................................................................................... 7-5

7.7 Turn-In Documentation ............................................................................. 7-5

7.8 Transportation of Hazardous Waste ......................................................... 7-6

7.9 Manifests................................................................................................... 7-7

7.10 Exception Reporting .............................................................................. 7-8

7.11 Recordkeeping ...................................................................................... 7-9

7.12 Hazardous Waste Reporting ............................................................... 7-10

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Section 8 Hazardous Waste Analysis Plan ........................................................... 8-1

8.1 General ..................................................................................................... 8-1

8.2 Analysis Cost ............................................................................................ 8-1

8.3 Chain-of-Custody Forms ........................................................................... 8-1

8.4 Results ...................................................................................................... 8-2

8.5 Characterization Frequency ...................................................................... 8-2

8.6 Unknown Wastes ...................................................................................... 8-2

8.7 Land Disposal Restrictions........................................................................ 8-3

Section 9 Hazardous Waste Minimization ............................................................. 9-1

9.1 Pollution Prevention Plan .......................................................................... 9-1

9.2 Hazardous Materials ................................................................................. 9-2

9.3 EMS Objectives and Targets .................................................................... 9-2

Section 10 Installation Waste Stream Summary ................................................... 10-1

10.1 General ............................................................................................... 10-1

10.2 Hazardous Waste ................................................................................ 10-1

10.3 Non-Hazardous Wastes ...................................................................... 10-2

10.4 Universal Waste .................................................................................. 10-2

10.5 Prohibited Items .................................................................................. 10-3

10.6 Polychlorinated Biphenyls ................................................................... 10-3

10.7 Regulated Medical Waste (RMW) ....................................................... 10-4

Section 11 Waste Stream Management ................................................................. 11-1

11.1 Absorbent Materials ............................................................................ 11-1

11.1.1 Continued Use Absorbents ........................................................ 11-1

11.1.2 Disposable Absorbents .............................................................. 11-2

11.1.3 Sweeping Compound ................................................................ 11-2

11.2 Adhesives ............................................................................................ 11-3

11.3 Aerosol Containers .............................................................................. 11-3

11.4 Antifreeze ............................................................................................ 11-3

11.5 Asbestos ............................................................................................. 11-4

11.6 Asphalt and Related Wastes ............................................................... 11-4

11.7 Batteries .............................................................................................. 11-4

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11.7.1 General Requirements ............................................................... 11-4

11.7.2 Small Rechargeable Batteries ................................................... 11-6

11.7.3 Lead Acid Batteries .................................................................... 11-6

11.8 Battery Fluid ........................................................................................ 11-7

11.9 Blast Media.......................................................................................... 11-7

11.10 Boiler Treatment .............................................................................. 11-8

11.11 Corrosion Prevention and Removal ................................................. 11-8

11.12 Cylinders .......................................................................................... 11-8

11.13 Empty Containers............................................................................. 11-9

11.14 Fuel ................................................................................................ 11-10

11.15 Fuel Filters ..................................................................................... 11-10

11.16 Grease and Related Items ............................................................. 11-11

11.17 Image Intensifier Tubes .................................................................. 11-11

11.18 Insect Repellant ............................................................................. 11-11

11.19 Medical Activities ........................................................................... 11-11

11.20 Mercury-Containing Lamps ............................................................ 11-12

11.21 Mercury-Containing Equipment ...................................................... 11-12

11.22 Military Munitions ........................................................................... 11-13

11.23 Nuclear, Biological, Chemical (NBC) Items .................................... 11-13

11.24 Paint Related Items ........................................................................ 11-13

11.24.1 Latex Paint ............................................................................. 11-13

11.24.2 Hazardous Waste Paint and Thinner ..................................... 11-14

11.24.3 Paint Containers .................................................................... 11-14

11.24.4 Paint Solids ............................................................................ 11-14

11.25 Parts Washer Solvent and Filters ................................................... 11-14

11.26 Pesticides, Herbicides, and Rodenticides ...................................... 11-15

11.27 Photo Processing Chemicals ......................................................... 11-16

11.28 Plating Shop Wastes ...................................................................... 11-16

11.29 Polychlorinated Biphenyls .............................................................. 11-16

11.30 Process Particulates ...................................................................... 11-17

11.31 Ration Heaters ............................................................................... 11-18

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11.32 Scrap Items .................................................................................... 11-18

11.32.1 Scrap Metal ............................................................................ 11-18

11.32.2 Items Requiring Special Handling .......................................... 11-18

11.33 Solder ............................................................................................. 11-19

11.34 Toner .............................................................................................. 11-19

11.35 Used Oil ......................................................................................... 11-19

11.36 Used Oil Filters .............................................................................. 11-20

11.37 Washrack Sand/Soil ....................................................................... 11-20

11.38 Weapons Cleaning Materials ......................................................... 11-20

11.39 X-Ray Rinse Water ........................................................................ 11-21

11.40 Zyglo Rinsate ................................................................................. 11-21

Section 12 Spill Response Procedures ................................................................. 12-1

12.1 General ............................................................................................... 12-1

12.2 Spill Response and Emergency Procedures ....................................... 12-1

12.3 Spill Contingency Plans ....................................................................... 12-2

12.4 Spill Contingency Training ................................................................... 12-3

12.5 Spill Contingency Supplies .................................................................. 12-3

12.6 Spill Reporting ..................................................................................... 12-3

LIST OF TABLES

Table 4-1 Maximum Concentration of Contaminants for the Toxicity Characteristic .... 4-6

LIST OF FIGURES Figure 2-1 Site Location Map ....................................................................................... 2-3

Figure 2-2 Installation Map ........................................................................................... 2-5

Figure 2-3 Hazardous Waste and Universal Waste Disposed per Year ..................... 2-11

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LIST OF APPENDICES Appendix A Waste Disposal Data CY10-CY15

Appendix B USAACE Form 2735, Hazardous Waste Job Description and Training

Record

Appendix C USAACE Form 2729, EO/EPOC Appointment Memo

Appendix D USAACE Form 2733, HWSAP and 90-Day HWAS Manager Appointment

Memo

Appendix E Inspection Forms (USAACE Form 2725, HWSAP Inspection Checklist;

USAACE Form 2726, 90-HWAS Inspection Log; USAACE Form 2711,

SPCC Plan Container Inspection Form; USAACE Form 2717,

Environmental Compliance Inspection Checklist)

Appendix F ADEM Letters and Guidance

Appendix G USAACE Form 2716, Secondary Containment Drainage Activity Log

Appendix H DD Form 1348-1A, Issue Release/Receipt Document

Appendix I 49 CFR 172.400 Excerpt

Appendix J EMS-WI-SW010, Contractor Hazardous Waste Management

Appendix K EMS-WI-SW001, Waste Turn-In Procedure

Appendix L Hazardous Waste Profile

Appendix M Container Labels

Appendix N USAACE Form 2730, Hazardous Material Authorization Request

Appendix O EMS-WI-SW009, Absorbent Continued Use Program

Appendix P USAACE Form 2732, Continued Use Absorbents Tracking Document

Appendix Q EMS-WI-SW002, Used Battery Management

Appendix R EMS-WI-SW007, Management of Used Oil and Fuel Filters

Appendix S EMS-WI-SW003, Used Lamps Management

Appendix T USAACE Form 2719, Site Specific Spill Plan

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ABBREVIATIONS AND ACRONYMS

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LIST OF ABBREVIATIONS AND ACRONYMS

90-HWAS 90-Day Hazardous Waste Accumulation Site ADEM Alabama Department of Environmental Management AMSS Aviation Maintenance Support Shop AR Army Regulation ASP Ammunition Supply Point CARC Chemical Agent Resistant Coating CFR Code of Federal Regulations CPAC Civilian Personnel Advisory Center CY Calendar Year DA Department of the Army DLADS Defense Logistics Agency Disposition Services DoD Department of Defense DPW Directorate of Public Works DPW-ENRD Directorate of Public Works, Environmental and Natural Resources

Division DS2 Decontamination Solution Number 2 EESOH-MIS Enterprise Environmental, Safety, and Occupational Health

Management Information System EMS Environmental Management System EMSMR Environmental Management System Management Representative EO Environmental Officer EPA Environmental Protection Agency EPOC Environmental Point of Contact EQCC Environmental Quality Control Committee FIFRA Federal Insecticide, Fungicide, and Rodenticide Act FRH Flameless Ration Heaters GAA Grease, Automotive and Aviation HID High Intensity Discharge HM Hazardous Material HM/HW Hazardous Material/Hazardous Waste HMCC Hazardous Material Control Center HMMP Hazardous Material Management Program HQDA Headquarters, Department of the Army HW Hazardous Waste HWAS Hazardous Waste Accumulation Site

ABBREVIATIONS AND ACRONYMS

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HWMP Hazardous Waste Management Plan HWSAP Hazardous Waste Satellite Accumulation Point ID Identification ISCP Installation Spill Contingency Plan LBP Lead-Based Paint LDR Land Disposal Restrictions LiSO2 Lithium Sulfur Dioxide LQG Large Quantity Generator LRC Logistics Readiness Center MOGAS Motor Gasoline MRE Meal Ready-to-Eat MRIP Munitions Rule Implementation Policy NBC Nuclear, Biological, and Chemical NDI Non-Destructive Investigation NiCd Nickel-Cadmium NiMH Nickel Metal Hydride NOV Notice of Violation NRC National Response Center P2 Pollution Prevention PAO Public Affairs Office PCB Polychlorinated Biphenyls POC Point of Contact POL Petroleum, Oil, and Lubricants PPE Personal Protective Equipment RCRA Resource Conservation and Recovery Act RMW Regulated Medical Waste SDS Safety Data Sheet SJA Staff Judge Advocate SOP Standard Operating Procedure SPCC Spill Prevention, Control and Countermeasures STB Super Tropical Bleach TSCA Toxic Substances Control Act TSD Treatment, Storage and Disposal UCMJ Uniform Code of Military Justice USAACE U.S. Army Aviation Center of Excellence WMM Waste Military Munitions

CONTACT LIST

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Contact List

Title Phone #

Chief, Environmental and Natural Resources Division 334-255-1659

Hazardous Waste Program Manager 334-255-1024

Solid Waste Program 334-255-1656

Recycling Manager 334-255-1658

Hazardous Waste Turn-In on Main Post Thursday 0900-1130 or by appointment (Office Hours 0730 to 1600 hrs.)

334-598-1311

DLADS Fort Rucker Office 334-255-2939

DLADS Representative (Eglin AFB) Comm. 850-882-8076/850-882-2824 or

DSN 872-8076/872-2824

Fire Department (for emergency, dial 911) 334-255-0044

Alabama Department of Environmental Management (ADEM) 1400 Coliseum Boulevard Montgomery, Alabama 36110-2400

334-271-7700

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SECTION ONE Introduction

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Section 1 Introduction

1.1 PURPOSE AND OBJECTIVE

The United States Army is committed to proper handling of the hazardous wastes that

are generated on its installations. The primary objective of this document is to provide a

plan that gives personnel working with hazardous waste the essential tools for effective

management. The purpose of this plan is to identify and establish the requirements for

the accumulation, storage, handling, and disposal of hazardous waste on Fort Rucker

from the point of generation to the point of disposal.

This plan was developed in accordance with Army Regulation (AR) 200-1, Environmental

Protection and Enhancement; the Alabama Department of Environmental Management

(ADEM) Administrative Code; and the Resource Conservation and Recovery Act (RCRA),

as amended. In the event that any of the provisions contained in this plan are superseded

or otherwise modified by changes to the Code of Federal Regulations (CFR) or the ADEM

Administrative Code, the CFR and ADEM Administrative Code will take precedence over

this plan.

This document implements the requirements of AR 200-1, Chapter 10-1 and provides

installation personnel with specific procedures and responsibilities to manage hazardous

wastes consistent with federal, state and local laws and regulations. The Hazardous

Waste Management Plan (HWMP) serves as documentation for regulatory authorities

that such a program is in place.

The HWMP documents personnel and procedures to ensure each step in the "cradle-to-

grave" management of hazardous wastes is carried out in a consistent manner and in

accordance with regulatory requirements. Procedures are either referenced or included

in this HWMP, as necessary, to provide documented hazardous waste management

instructions, from the time of waste generation until it is transported offsite for reuse or

disposal.

1.2 APPLICABILITY

The HWMP is intended to be comprehensive, covering all operations involving hazardous

waste, including all activities and tenants that generate or otherwise manage hazardous

waste, including those activities located at facilities outside the contiguous boundary of


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Fort Rucker. The requirements of this document are applicable to all military, civilian and

contract personnel at Fort Rucker, including commanders and directors.

1.3 IMPLEMENTATION

Implementation of a comprehensive hazardous waste management program mandated

by RCRA requires maximum cooperation of all activities on Fort Rucker. It is the

responsibility of the Garrison Commander to ensure compliance with all RCRA

requirements for Fort Rucker and to notify and report to Environmental Protection Agency

(EPA) or ADEM, as required, for all installation activities, including tenant activities. The

individual installation organizations (generating activities) are accountable for conducting

their activities in accordance with this plan. Each generating organization will ensure

compliance with RCRA regulations at the facility.

1.4 FORT RUCKER ENVIRONMENTAL MANAGEMENT SYSTEM

Hazardous waste is one of the significant aspects identified within the Fort Rucker

Environmental Management System (EMS). This HWMP serves as an operational control

as specified in EMS-P016, Operational Controls Procedure. This document is a controlled

document with the official version maintained on the Sustainable Fort Rucker website

(www.fortrucker-env.com). All forms and work instructions referenced within this

document are also controlled documents. Forms and work instructions are included in the

appendices for reference only; the official versions of all documents are maintained on

the Sustainable Fort Rucker website. The following tables should be used to document

plan review and amendments.

1.4.1 Plan Review This plan will be reviewed at least annually and when a process change occurs. The

review will be documented in the following table.

Date Review Completed Signature of Person Performing Review Comments


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1.4.2 Revision Log Revisions made to the plan, including the date of the revision, the section of the plan

being revised, the reason for the change, and the signature of the person making the

change will be documented in the following table.

Date of Change

Page Numbers/ Section

Signature of Person Performing Review Reason for Change


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SECTION TWO Installation and Regulatory Overview

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Section 2 Installation and Regulatory Overview

2.1 GENERAL

Fort Rucker is located in southeast Alabama, 20 miles northwest of Dothan, Alabama. It

is surrounded by the towns of Daleville on the south, Enterprise on the west, and Ozark

on the east (Figure 2-1). Fort Rucker is positioned in a topographical area of southeastern

Alabama that consists of moderately rolling lands with elevations ranging from 200 to 300

feet above mean sea level.

The installation spans over two Alabama counties, Dale and Coffee, and covers a total of

62,321 acres, which is composed of 57,885 acres at the main post, 1,297 acres at Cairns

Army Airfield, 247 acres at Shell Army Heliport, 1,220 acres at small stagefields within a

five-county area, and 1,672 acres of leases and easements. The airfields, heliports, and

stagefields are listed below and depicted in Figure 2-2. The various fields are indicated

with only the name and not the type of field when they are discussed within this document.

• Allen Stagefield

• Brown Stagefield

• Cairns Army Airfield

• Ech Stagefield

• Goldberg Stagefield

• Guthrie Airfield (not active)

• Hanchey Army Heliport

• Hatch Stagefield

• Highbluff Stagefield

• Highfalls Stagefield

• Hooper Stagefield

• Hunt Stagefield

• Knox Army Heliport

• Louisville Stagefield

• Lowe Army Heliport

• Lucas Stagefield

• Molinelli Stagefield


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• Runkle Stagefield

• Shell Army Heliport

• Skelly Stagefield

• Stinson Stagefield

• Tabernacle Stagefield

• Tac-X Stagefield

• Toth Stagefield

• Wolfpit Tactical Site

The primary missions of Fort Rucker are pilot training, aircraft maintenance, and air traffic

control training with emphasis on rotary-wing aircraft. Hazardous wastes are generated

primarily as the result of maintenance of Army equipment and property as well as from

expired hazardous materials. These wastes are generated and managed at numerous

locations across Fort Rucker.


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Figure 2-1 Site Location Map


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2-5

Figure 2-2 Installation Map


2-6



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2.2 REGULATORY AUTHORITY

2.2.1 Federal Regulations RCRA is the principal Federal legislation governing the management of solid and

hazardous waste. The EPA has established regulations under RCRA which govern

hazardous waste generation, storage, transportation, and disposal under Title 40 of the

CFR Parts 260 through 299.

• Part 260 provides general guidance for the use of the regulations and sets forth

provisions, which are applicable to all parts.

• Part 261 identifies and lists various wastes considered by EPA to be hazardous.

This part establishes the criteria by which wastes are characterized as hazardous.

• Part 262 establishes standards applicable to generators of hazardous waste,

including requirements for reporting and manifesting of hazardous waste

shipments.

• Part 263 establishes standards for transporters of hazardous wastes including

manifesting and recordkeeping.

• Part 264 establishes standards for owners and operators of hazardous waste

treatment, storage, and disposal (TSD) facilities.

• Part 265 establishes interim status standards for owners and operators of

hazardous waste TSD facilities. These are the standards with which existing

facilities must comply if they are to remain in operation until EPA takes final action

on their permit applications.

• Part 268 provides land disposal restrictions (LDR).

• Part 273 provides standards for Universal Waste Management.

• Part 279 provides standards for the management of used oil.

2.2.2 State Regulations On December 22, 1987, the State of Alabama was granted final authorization from the

EPA to operate its own hazardous waste management program. The authorization,

however, is subject to the authority retained by EPA in accordance with the Hazardous

and Solid Waste Amendments (HSWA) of 1984. Generators, transporters, and

owners/operators of hazardous waste TSD facilities in Alabama are now subject to the


2-8

Alabama Hazardous Waste Management Rules in lieu of the Federal regulations adopted

by the EPA.

ADEM has been designated the lead agency in developing and administering the

hazardous waste management program in Alabama.

The Alabama Hazardous Waste Management Rules are contained in the ADEM

Administrative Code, Land Division - Hazardous Waste Program - Division 14. The State

of Alabama has essentially adopted the Federal hazardous waste regulations. Some of

Alabama’s requirements are more stringent than the federal requirements. Any

management requirements that are stricter than federal requirements are specified in the

appropriate section of this plan. In Alabama, any generator (including small quantity

generators who are partially exempt under RCRA) may be required to obtain approval

before transporting, treating, or disposing of certain types of hazardous waste. The

following sections are included in the ADEM Administrative Code:

• Chapter 335-14-1 - Hazardous Waste Management System: General

• Chapter 335-14-2 - Identification and Listing of Hazardous Waste

• Chapter 335-14-3 - Standards Applicable to Generators of Hazardous Waste

• Chapter 335-14-4 - Standards Applicable to Transporters of Hazardous Waste

• Chapter 335-14-5 - Standards for Owners and Operators of Hazardous Waste

Treatment, Storage and Disposal Facilities

• Chapter 335-14-6 - Interim Status Standards for Owners and Operators of

Hazardous Waste Treatment, Storage and Disposal Facilities

• Chapter 335-14-7 - Standards for the Management of Specific Hazardous Wastes

and Specific Types of Hazardous Waste Management Facilities

• Chapter 335-14-8 - Permit Program

• Chapter 335-14-9 - Land Disposal Restrictions

• Chapter 335-14-11 - Standards for Universal Waste Management

• Chapter 335-14-17 - Standards for the Management of Used Oil

2.2.3 Army Regulations The Army is committed to environmental stewardship in all actions as an integral part of

the Army mission. Department of Defense (DOD) installations and personnel are required


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to comply with all federal, state, and local laws, as well as Army requirements, designed

to protect human health and the environment. Pursuant to this requirement, the

Department of the Army (DA) has developed AR 200-1, Environmental Protection and

Enhancement, which prescribes responsibilities, policies, and procedures to preserve,

protect, and restore the quality of the environment. This regulation is to be implemented

in a number of areas, including hazardous waste management. The procedures in

Chapter 10 of AR 200-1 incorporate all applicable regulatory requirements for hazardous

waste management, and specify implementation of local procedures and responsibilities

for execution of the hazardous waste management program. Chapter 10, Waste

Management, further defines the policy for managing hazardous and solid wastes.

Related policy guidance on solid waste may be found in AR 420-1, Army Facilities

Management. Specifically, Fort Rucker should ensure that waste accumulation, storage,

or transfer facilities are designed and constructed to prevent releases to the environment.

This document includes the elements of a HWMP required by AR 200-1:

Chapter 10-1.d.(3) 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 hazardous waste management, to include the

identification, storage, and transporting of HW; training of personnel; tracking

manifests; and maintaining required records.

2.2.4 Fort Rucker Policies Regulatory Compliance

It is an installation policy that any command, activity, tenant, organization, or contractor

at Fort Rucker that generates or otherwise manages hazardous waste, is subject to and

shall comply with all applicable federal, state, local, Army and installation requirements.

The Directorate of Public Works, Environmental and Natural Resources Division (DPW-

ENRD) is responsible for administering the Fort Rucker HWMP. Any person found to be

violating the provisions of any of these requirements is subject to appropriate disciplinary

measures. In the absence of appropriate regulatory guidelines, hazardous waste shall be


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managed in a manner that minimizes adverse effects to human health and the

environment.

Standard Operating Procedures

Standard operating procedures (SOPs) for hazardous waste - including but not limited to

hazardous waste accumulation, auditing/inspection, storage, and turn-in procedures -

shall be implemented by all activities on the installation that generate hazardous waste.

Current SOPs for activities that generate hazardous waste at Fort Rucker are included in

the EMS Master Document List as Work Instructions. The EMS Master Document List is

available on the Sustainable Fort Rucker website.

Waste Minimization

Potential hazardous wastes will be recycled and reused to the maximum extent

practicable at Fort Rucker. Hazardous wastes, which are not economically recoverable,

shall be disposed in a way that will prevent or minimize pollution of the environment and

in compliance with federal, state, and local hazardous waste regulations. Emphasis will

be placed on source reduction and materials substitution methods.

Army military, civil works activities, and tenants are required to establish procedures and

responsibilities for the execution of the waste management program which emphasizes

pollution prevention, chain of command, and individual responsibility to achieve

compliance and minimize waste generation, treatment, and disposal through pollution

prevention actions.

2.3 RCRA GENERATOR STATUS

Waste is generated as a result of many types of installation activities, including vehicle

and aircraft maintenance; military training activities; fuel and hazardous material spills;

medical operations; battery shops; and construction projects. Waste is generated by

military, civilian, and contractor personnel working on Fort Rucker. Appendix A contains

waste generation data for the largest waste streams at Fort Rucker.

Fort Rucker is a large quantity generator, generating 17 tons of hazardous waste in CY15.

Figure 2-3 shows the quantities of hazardous waste and universal waste disposed from

CY10 through CY15.


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Figure 2-3 Hazardous Waste and Universal Waste Disposed per Year

0

10

20

30

40

50

60

70

CY10 CY11 CY12 CY13 CY14 CY15

Haz

ardo

us W

aste

and

Uni

vers

al W

aste

Dis

spos

ed

(tons

)

Hazardous Waste

Universal Waste


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2.4 EPA IDENTIFICATION (ID) NUMBER

Fort Rucker is a large quantity generator (e.g. greater than 1000 kg per month) of

hazardous waste. The Fort Rucker EPA/State identification (ID) number for generating

hazardous waste is AL6210020776.

Cairns Army Airfield is not contiguous to Fort Rucker and is a large quantity generator.

The EPA/State ID number for Cairns for generating hazardous waste is AL9210090040.

Additionally, Shell Army Heliport is not contiguous to Fort Rucker and is a small quantity

generator. The EPA/State ID number for Shell for generating hazardous waste is

AL2210090039.

2.5 HAZARDOUS WASTE ACCUMULATION SITES (HWAS)

Currently, Fort Rucker has five 90-day Hazardous Waste Accumulation Sites (90-HWAS).

If operational conditions require closure of one of the 90-HWAS, it will be closed in

accordance with ADEM Administrative Code Chapter 335-14-3-.03(5)(a)5. This section

requires compliance with the closure requirements of 335-14-3-.03 and the applicable

requirements of 335-14-6-.09(9), 335-14-6-.10(8), 335-14-6-.23(6), and 335-14-6-.30(3),

and the record keeping requirements of rules 335-14-3-.04(1)(c) and 335-14-3-.04(4).

These 90-HWAS are located as follows:

1. Building 1207

2. Near Building 1001

3. Near the Lowe Army Heliport washrack

4. Near the Hanchey Army Heliport washrack

5. At Cairns Field between Hangars 30103 and 30104

Additionally, Fort Rucker operates a 180-day HWAS at Shell Army Heliport. Shell Field is

a small quantity generator, and the HWAS is a 180-day site. Fort Rucker manages this

HWAS with the same practices as at a 90-HWAS. Any references to requirements for a

90-HWAS are also applicable to the accumulation site at Shell.


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2.6 GENERAL HAZARDOUS WASTE TRAINING REQUIREMENTS

This section provides general information related to the level of training required by all

personnel who manage or supervise hazardous waste activities or handle hazardous

waste in the course of their employment duties. The training shall be implemented by all

Fort Rucker installation and tenant activities. Information about the overall training

program is included in EMS-P014, Competence Based Training.

Federal and state regulations require that all personnel managing or handling hazardous

waste must be trained, either through classroom instruction or on-the-job-training, to

respond to emergencies, protect the environment, and properly handle and dispose of

hazardous wastes. The regulatory requirements for training may be found in ADEM,

Division 14, 335-14-5-.02(7).

Facility personnel whose duties have a direct effect on hazardous waste management

and/or hazardous waste accumulation, whether by direct contact with the hazardous

waste or through hazardous waste management activities, must receive training. Each

person managing or handling hazardous waste must receive introductory and annual

update hazardous waste training corresponding with his/her responsibilities. The annual

update training must be completed within 365 days of the previous training.

The introductory training must be completed within six months of the date on which the

employee begins work in a position requiring such training. Employees must be

immediately and continuously supervised when performing hazardous waste duties until

such training is completed.

At a minimum, all supervisors and managers of hazardous waste activities will be trained

in installation-sponsored or off-site training courses that meet the established training

requirements of this plan. It is their responsibility to ensure that personnel working for

them are trained either in formal courses or in-house using on-the-job-training and "shop

level" training classes to meet the regulatory requirements.

Personnel responsible for shipping hazardous waste and signing hazardous waste

manifests must be trained in accordance with Department of Transportation (DOT) 49


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CFR 172, Subpart H, which requires initial and recurrent training. Only personnel within

DPW-ENRD designated by the Garrison Commander are authorized to sign manifests.

Each organization will develop a program to train its hazardous waste handlers, using an

appropriate combination of the following:

• Installation-sponsored hazardous waste training courses

o DOD Hazardous Material / Hazardous Waste (HM/HW) Handler Course –

24-hour initial training / 8-hour refresher training annually

o Hazardous Waste Satellite Accumulation Point (HWSAP) Manager Course

– 2-hour training annually

o 90-HWAS Manager Course – 2-hour training annually

• Off-site hazardous waste training courses

• Organization level training such as shop talks, lectures, and guest lectures

• Reading and discussing installation and organization level hazardous waste

management plans, SOPs, and spill contingency plans

• On-the-job instruction in hazardous waste management procedures from a person

trained in those procedures

• Performance of hazardous waste management procedures under the direct

supervision of a person trained in those procedures

All instances of training must be documented using USAACE Form 2735, Hazardous

Waste Job Description and Training Record, contained in Appendix B or otherwise

approved by DPW-ENRD in writing. The training record must include:

• Name of Employee

• Job Title

• Job Description

• A written description of the type and amount of both introductory and continued

training that will be given to each person filling a position.

• Records that document that the training required has been given to, and completed

by, facility personnel.


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A training record must be maintained on-site for every person in the organization requiring

hazardous waste training. Individual records of training are required by state and federal

regulations to be maintained for three years after an employee leaves employment at the

organization. Training records may be transferred with an employee if the employee is

transferred to another job at the facility.


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SECTION THREE Responsibilities

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Section 3 Responsibilities

3.1 GENERAL

Environmental compliance is both a command and an individual responsibility.

Commanders and heads of activities at all levels on and around Fort Rucker are

responsible for compliance with this HWMP. Responsibilities for implementing this plan

are distributed throughout installation organizations that generate, accumulate, transport,

turn-in, monitor, or respond to incidents involving hazardous waste. Overall compliance

with federal, state, and local hazardous waste laws and Army regulations is the

responsibility of the installation commander through the Environmental Management

System (EMS). This section specifies the responsibilities of all installation activities and

personnel (military, civilian, and contractors) in generating and accumulating hazardous

waste.

3.2 GARRISON COMMANDER

a. Ensures that Fort Rucker is compliant with all applicable environmental laws and

regulations.

b. Programs and budgets for the necessary funds and personnel in order to execute

a hazardous waste program and comply with applicable state, federal, and Army

regulations.

c. Serves as the chairperson of the EQCC which meets quarterly to discuss and

oversee pertinent environmental issues.

d. Signs RCRA permit applications, compliance agreements, consent orders, and

responses to Notices of Violation (NOV) with the state and federal regulatory

officials, following review by the installation Staff Judge Advocate (SJA) and the

Directorate of Public Works (DPW).

e. Establishes an organizational structure to plan, execute and monitor hazardous

waste programs and waste minimization initiatives.

f. Delegates the preparation and signature of all shipping manifests required by

federal and state law for wastes to appropriately trained personnel within DPW.


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3.3 ENVIRONMENTAL QUALITY CONTROL COMMITTEE (EQCC)

a. Provides the Garrison Commander with a regularly scheduled status report on

environmental issues and actions, including those involving hazardous wastes and

materials.

b. Provides a forum for dissemination of information and a forum for the principal

parties responsible for environmental and occupational health to introduce and

resolve environmental issues.

c. Increases the awareness and active participation at all organizational levels in

meeting all the laws and regulatory requirements.

d. Ensures that management of hazardous waste on the installation complies with

applicable portions of ADEM Administrative Code Division 14 and 40 CFR Parts

260-279.

e. Ensures all enforcement actions are resolved quickly.

3.4 COMMANDERS, DIRECTORS, AND SUPERVISORS (MILITARY, CIVILIAN, AND CONTRACTORS)

The commander/director of each major subordinate command, brigade, battalion,

directorate, tenant organization, and civilian contractor that handles hazardous

materials/waste will:

a. Appoint in writing military personnel, civilian or contractor supervisors as

Environmental Officer (EO) or Environmental Points of Contact (EPOC) using

USAACE Form 2729, Environmental Officer and EPOC Appointment Memo, a

copy of which is located in Appendix C. See the Fort Rucker Environmental Officer

Appointment and Training Plan and the Fort Rucker Environmental Officer Policy

for additional information. Both of these documents are available on the

Sustainable Fort Rucker website.

b. Appoint in writing military personnel, civilian or contactor supervisors as 90-HWAS

and/or HWSAP managers (whichever is appropriate) using USAACE Form 2733,

HWSAP and HWAS Manager Appointment Memo, for all activities within their area

of responsibility that generate, manage, accumulate, store, and/or transport

hazardous waste. A copy of this form is located in Appendix D.


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c. Identify all hazardous waste handlers within areas of responsibility. Identify the

location of all HWSAP and 90-HWAS within their organization, and submit an

updated list to DPW-ENRD at least annually (prior to October 1 of each year).

Provide written notification to the DPW-ENRD Hazardous Waste Program

Manager if any changes to waste streams or accumulation areas occur between

list submissions. Any proposed change, including adding or removing

accumulation areas or waste streams, should be coordinated with DPW-ENRD

prior to implementation.

d. Set organization-level hazardous waste management policy and establish an

active hazardous waste management program in compliance with all pertinent

laws and regulations and the Fort Rucker HWMP.

e. Ensure waste profile information changes (e.g. change in chemicals used, change

in safety data sheets [SDS], etc.) are communicated to DPW-ENRD prior to waste

accumulation.

f. Ensure that all hazardous waste managers and handlers are trained in accordance

with this HWMP.

g. Ensure that all personnel who may be exposed to hazardous waste in the course

of their work are made aware of the hazards to which they are exposed as well as

the precautions required to protect both the environment and themselves in

operational areas.

h. Ensure that materials and supplies, including the necessary and proper fitting of

personal protective equipment (PPE) and emergency response supplies, are

provided for the proper management and handling of hazardous waste.

i. Ensure notices from state or federal environmental agencies, including

enforcement actions and NOVs, noncompliance or administrative orders or

compliance requests, are forwarded within 24-hours to the Garrison Commander

with a notification copy to their command. Ensure that appropriate action is taken

to address negligent and willful violations of federal and state hazardous waste

laws and regulations, to correct operational deficiencies, and to prevent

reoccurrence of violations.


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j. Prepare a Site Specific Spill Plan as specified in Appendix A of the Installation Spill

Contingency Plan (ISCP), which includes a contingency plan, for the storage and

management of hazardous waste for each 90-HWAS and HWSAP.

k. Ensure that all hazardous waste handlers obtain the initial mandatory training

program described in Section 5.8 and 6.9 within 60 days, and complete the initial

training program within six months of the date of their employment in or assignment

to the waste handling position. Ensure that newly assigned personnel do not work

in unsupervised positions until they have completed the initial training program.

Further, they ensure that all hazardous waste handlers complete the required

refresher training on an annual basis.

l. Ensure that the training records are maintained and kept at or near the 90-HWAS.

The records should document that the hazardous waste handlers have completed

the training. Training records on employees must be maintained during the course

of their employment and retained for at least three years past the date the

employees last worked within the organization.

m. Become familiar with the installation hazardous waste minimization goals in

accordance with Section 10 of this plan and implement as appropriate or as

required.

n. Units, tenants, and activities generating hazardous waste are responsible for

estimating annual hazardous waste disposal costs and including in budget

forecast.

3.5 HAZARDOUS WASTE SATELLITE ACCUMULATION POINT (HWSAP) MANAGERS

a. Serve as points of contact regarding the implementation of their hazardous waste

management program responsibilities within the installation or tenant organization.

b. Ensure an up-to-date appointment letter using USAACE Form 2733, HWSAP and

HWAS Manager Appointment Memo, from their supervisor/commander is readily

available and that the letter has been submitted to DPW-ENRD prior to performing

hazardous waste management duties. A copy of this form is located in Appendix D.

c. Ensure that all hazardous waste is placed in a DPW-ENRD approved HWSAP.


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d. Ensure the appropriate information and warning signs are posted at each HWSAP.

HWSAP signs should include the following information: Hazardous Waste Satellite

Accumulation Point, HWSAP Manager Name and his/her telephone number, along

with the Alternate HWSAP Manager name and telephone number.

e. Ensure that appropriate EPA markings are on the hazardous waste label or

container, and represent the waste within:

• The words "HAZARDOUS WASTE"

• Description of the contents

• EPA ID number

• EPA Waste Code(s)

• Accumulation Start Date if the container is full.

f. Advise the Hazardous Waste Program Manager of any changes in chemicals or

processes that may impact the appropriate EPA markings on the waste container.

g. Ensure that appropriate EPA markings are on universal waste labels or containers:

• The words "UNIVERSAL WASTE"

• The words “Used Lamps”, “Used Mercury Thermostats”, “Used Batteries”, or

“Waste Pesticides” (as appropriate)

• The accumulation start date, which is the date the first item is placed in the

container.

h. Ensure that accurate descriptions including the weights (in pounds) and volumes

of containers are recorded on DD Forms 1348-1A for all hazardous waste and

universal waste containers being turned in to the 90-HWAS. If scales are not

available at the HWSAP, the weight may be added to the form at the 90-HWAS.

i. Ensure appropriate and authorized containers are used that are capable of being

labeled, handled, loaded, and transported following management procedures in

the areas where hazardous and universal wastes are being generated in their

activities.

j. Ensure hazardous waste at the HWSAP is removed within three calendar days of

reaching the accumulation volume limit of 55 gallons of hazardous waste or one

quart of acutely hazardous waste and are turned in to the 90-HWAS.


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k. Ensure that universal waste containers are moved to a 90-HWAS within six months

of the start date.

l. Maintain hazardous waste containers in proper condition, e.g., no pitting, no sharp

edge creases or dents, no material defects, no bulging heads, and no excessive

rust.

m. Ensure that containers are kept closed except when they are being filled.

n. Ensure proper segregation into containers to prevent co-mingling with other

hazardous or non-hazardous materials.

o. Maintain Site Specific Spill Plans for each of their activities using USAACE Form

2719, which is found in Appendix T.

p. Ensure that personnel (including themselves) who handle hazardous waste in their

areas of responsibility are trained as appropriate to the duties that they perform.

HWSAP managers should annually attend the HWSAP Manager Course offered

by DPW-ENRD. HWSAP managers may also attend the DOD HM/HW Handler

Course if recommended by their supervisors, but this training is not required for

HWSAP managers.

q. Ensure that an approved fire extinguisher is readily available if flammable

hazardous waste is handled at the HWSAP.

r. Ensure that a spill kit is accessible in areas where liquid wastes are generated.

s. Perform weekly inspections of the HWSAP. Personnel should use USAACE Form

2725, HWSAP Inspection Checklist, for weekly (every 7 days) inspections. A copy

of this checklist may be found in Appendix E, but the official version of all EMS

documents is maintained on the Sustainable Fort Rucker website.

3.6 90-HWAS MANAGERS

The 90-HWAS Managers are the supervisors directly responsible for the hazardous waste

being stored at the 90-HWAS.

a. Ensure that they have an up-to-date appointment letter from their supervisor or

commander using USAACE Form 2733, HWSAP and HWAS Manager

Appointment Memo (see Appendix D), and that the letter has been submitted to

the DPW-ENRD prior to performing the required tasks. At a minimum, each site


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will have an accumulation site manager and an alternate manager formally

appointed, and each manager will have received initial and annual refresher

training in accordance with applicable federal and state regulations.

b. Attend training specified by DPW-ENRD, including the initial DOD HM/HW Handler

Course and annual refresher course as well as the DPW-ENRD 90-HWAS

Manager Course annually.

c. Coordinate with DPW-ENRD if relocation of a 90-HWAS is necessary.

d. Act as initial spill coordinators until the installation on-scene coordinator arrives in

the event of a hazardous waste spill in their areas of responsibility. Any person

discovering a spill or release of a hazardous substance or waste must immediately

report the incident to his/her supervisor.

e. Ensure accountability of all hazardous waste by maintaining an inventory of wastes

at each site. Inventories will include the accumulation start date, the date the

container was received within the site, the date the container was removed from

the site, the document number on the DD Form 1348-1A and the profile number of

each container.

f. Ensure that appropriate EPA Markings are on the hazardous waste label or

container to include the EPA ID number, the words "HAZARDOUS WASTE",

proper shipping name, EPA Waste Code(s), and Accumulation Start Date.

g. Ensure that hazardous waste is managed in accordance with the Fort Rucker

HWMP and appropriate federal, state, local, and Army regulations.

h. Ensure that containers are properly segregated and compatible with the waste.

Advise the Hazardous Waste Program Manager of any changes in chemicals or

processes that may impact the appropriate EPA markings on the waste container.

i. Inspect and document assigned 90-HWAS weekly (every 7 days) using USAACE

Form 2726, HW 90-Day Accumulation Area Inspection Log. A copy of this form is

located in Appendix E.

j. Ensure the appropriate warning signs are posted at all approaches to the 90-

HWAS. Signs are to include the words “Hazardous Waste Accumulation Site”, and

“In Case of Emergency Call (telephone number)”.


3-8

k. Ensure the DD Form 1348-1A is completed when receiving a waste container. For

Cairns, Shell, and Main Post 90-HWAS, submit copies of the completed DD 1348-

1A to DPW-ENRD weekly.

l. Ensure that a communication device, a spill kit, and the Site Specific Spill Plan are

available at (or near) the 90-HWAS.

m. Ensure that an approved fire extinguisher is readily available if flammable

hazardous waste is handled at the 90-HWAS.

n. Maintain on file all hazardous waste management records and documents for the

specific accumulation site, in accordance with procedures outlined in Section 5 of

this HWMP. For Cairns, Shell, and Main Post 90-HWAS, report containers in a 90-

HWAS over 60 days to DPW-ENRD. For Hanchey, Lowe, and AMSS, transfer

waste to the Main Post 90-HWAS within two weeks of receipt.

3.7 PERSONNEL WORKING WITH HAZARDOUS WASTES

a. Contain and clean-up spills of known materials immediately when practical, and

follow the procedures in the Site Specific Spill Plan for the work site.

b. Report hazardous waste spills to supervisor or commander. See the ISCP and

Spill Prevention, Control, and Countermeasures (SPCC) Plan for additional

information.

c. Place hazardous waste in designated containers that are properly labeled for the

waste.

d. Never place hazardous waste in a trash container or dumpster. Also, never pour

waste down a sanitary or storm drain or on the ground. Properly manage all

hazardous waste in accordance with this HWMP.

e. Wear the appropriate protective clothing when handling hazardous wastes.

f. Seek the appropriate training from their supervisors to perform specific jobs.

3.8 EO AND EPOC

a. Attend the two-day Environmental Officer Training Course upon initial assignment

and the 4-hour refresher course annually. Only the 4-hour course is required for

EPOCs.

b. Serve as the organization’s primary environmental contact.


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c. Ensure implementation and compliance with this plan for their organization.

d. Manage the organization’s environmental training and certification records.

e. Identify all organizational positions that require mandated training, such as

hazardous waste management.

f. Conduct on-the-job training for shop-level personnel.

3.9 DIRECTOR OF PUBLIC WORKS

a. Oversees the administration of the hazardous waste management program.

b. Provides resources for the overall management of the Fort Rucker EMS.

c. Ensures proper submittal of all permits, manifests, audits, checklists, reports,

plans, and payments of fees or fines, as required by DOD, Army, federal, and state

regulatory agencies.

d. Ensures DPW-ENRD has all resources necessary to implement the hazardous

waste requirements described in this plan.

e. Coordinates all inspections of Fort Rucker by federal and state regulatory

agencies.

3.10 DPW-ENRD

a. Manages the installation hazardous waste management program and develops

overall management policies for HW, including but not limited to hazardous waste

accumulation and storage policies, on-site auditing/inspection procedures, and

turn-in procedures.

b. Incorporates hazardous waste objectives and targets into the EMS utilizing

USAACE Form 2724, Objectives and Targets Action Plan.

c. Develops, implements, updates, maintains, and distributes an overall Hazardous

Waste Management Plan for the installation, which includes guidance to all

activities for the proper handling of hazardous waste.

d. Signs hazardous waste manifests, as delegated by the Garrison Commander, and

prepares hazardous waste reports and compliance documentation as required by

federal, state, local, and Army regulations. Ensures appropriate hazardous waste

manifests are prepared for hazardous waste in accordance with DOT, ADEM, and

EPA requirements for transportation and disposal, respectively. Manages manifest


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requirements, including signing for the commander, tracking manifest from cradle-

to-grave, publishing exception reports, and maintaining other associated

documentation, as required, for all waste not shipped through the Defense

Logistics Agency Disposition Services (DLADS).

e. Perform and maintain records of hazardous waste quarterly compliance

inspections conducted using USAACE Form 2717, Environmental Compliance

Inspection Checklist. A copy of the sections applicable to hazardous waste

management is included in Appendix E.

f. Prepares permit applications as required.

g. Assists organizations by providing guidance with hazardous waste

characterization, accumulation, storage, marking and labeling, waste minimization,

waste recycling, and waste turn-in and disposal.

h. Profiles waste streams generated by the installation activities based on information

provided by the installation, tenant, and contract organization managers; SDSs; or

laboratory analysis.

i. Coordinates and submits required regulatory reports and documents relating to the

installation's hazardous waste management program except as otherwise directed

by the Garrison Commander.

j. Maintains files of reports, documents, and records required by pertinent

environmental laws and regulations.

k. Coordinates the establishment and/or relocation of HWSAPs and 90-HWASs in

support of the performance of organization’s missions. Ensures that the

establishing of these storage areas is in accordance with the requirements of

Sections 5 and 6.

l. Serves as the technical director and advisor for mandatory hazardous waste

training programs that provide required training for all organization EOs and

hazardous waste handlers.

m. Maintains an inventory of hazardous waste on the installation through the use of

hazardous waste turn-in documentation submitted by generating activities.


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n. Conducts periodic inspections of generator accumulation points and areas to

ensure that hazardous waste is being handled, stored, and turned in according to

the policies and procedures set forth in this HWMP.

o. Provides ongoing guidance to generating activities for the proper handling and

disposal of hazardous waste.

p. Monitors the progress of all activities in achieving the hazardous waste reduction

goals approved in the installation Pollution Prevention Plan.

3.11 DEFENSE LOGISTICS AGENCY DISPOSITION SERVICES (DLADS) EGLIN

The Defense Reutilization and Marketing Office (DRMO) has changed its name to the

Defense Logistics Agency Disposition Service (DLADS). The services offered by DLADS

are essentially the same as those previously provided by DRMO. DPW-ENRD will assist

organizations with any process modifications that may result from this change.

a. Coordinate timely disposition of hazardous waste to off-site permitted TSD facilities

by providing contracting support for procurement of hazardous waste

transportation and disposal services as well as hazardous property reutilizations.

b. Travel to Fort Rucker each time there is a hazardous waste pick-up by the

hazardous waste disposal contractor and serve as the Contracting Officer’s

Representative.

c. Ensure that the transporter is properly certified by the EPA, the State of Alabama,

and other states to transport hazardous waste and that the transporter provides

both a vehicle and a driver licensed to load and haul hazardous waste.

d. Ensure that the contracted disposal services comply with federal and state

hazardous waste regulations.

e. Verify accuracy of hazardous waste weight measurements prior to waste

acceptance.

3.12 PUBLIC AFFAIRS OFFICE (PAO)

a. Acts as the focal point for inquiries from the news media and concerned citizens

regarding hazardous waste and in the event of a hazardous waste incident or

accident.


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b. Assists the on-scene coordinator during hazardous waste incidents by keeping

interested news media and the public aware of events and curtailing rumors

through the dissemination of coordinated, accurate information. Responds to the

accident/incident site, to the command post, and to the Public Affairs duty section

where an information center may be established.

c. The presence of hazardous waste in a contained area will probably not constitute

reasonable cause to forcibly deny access to the area by accredited news media

representatives. Applicable security and safety provisions will apply, however.

Under no circumstances will Public Affairs Office (PAO) personnel escort news

media representatives into a hazardous or potentially dangerous area without

permission from the on-scene coordinator.

3.13 LOGISTICS READINESS CENTER (LRC)

a. Manages hazardous material requisition, receipt, and distribution through the

Hazardous Material Control Center (HMCC).

b. Inducts all organizations and activities on Fort Rucker into the HMCC system and

implements product substitution, shelf-life management, and proper storage

requirements.

c. Maintains online SDS database.

3.14 CIVILIAN PERSONNEL ADVISORY CENTER (CPAC)

a. Validates training and ensures job descriptions are amended for all civilian

employees involved with hazardous waste management/training.

SECTION FOUR Hazardous Waste Identification and Classification

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Section 4 Hazardous Waste Identification and Classification

4.1 GENERAL

Solid waste is any garbage, refuse, sludge, liquid, semi-solid, or contained gaseous

material resulting from industrial, commercial, mining, and agricultural activity. A material

is a solid waste after it has been used for its intended purpose, when it is discarded by

being abandoned, and sometimes when it is recycled. After an item has been determined

to be a solid waste, a hazardous waste determination must be made. Please contact the

DPW-ENRD Hazardous Waste Program Manager for assistance. All hazardous wastes

must meet the following criteria:

• Not specifically excluded or exempted by RCRA; and

• Is a RCRA “Listed” waste, or

• Exhibits a characteristic of hazardous waste.

4.2 EXEMPTIONS FROM HAZARDOUS WASTE DEFINITION

ADEM Administrative Code 335-14-2-.01(4)(a)-(b) and 40 CFR 261.4 define materials

that are exempt from definition as a hazardous waste. Exemptions from RCRA hazardous

waste commonly encountered at Fort Rucker include:

• Household waste (ADEM Administrative Code 335-14-2-.01(4)(b)1 / 40 CFR

261.4(b)(1)).

• Solid waste consisting of discarded arsenical-treated wood (pressure treated

lumber) or wood products which fails the test for the Toxicity Characteristic (waste

codes D004 to D017) and is not a hazardous waste for any other reason if the

waste is generated by persons who use the arsenical-treated wood and wood

products (ADEM Administrative Code 335-14-2-.01(4)(b)9 / 40 CFR 261.4(b)(9)).

• Petroleum-contaminated media and debris that fail the test for the Toxicity

Characteristic of ADEM Administrative Code 335-14-2-.03(5) / 40 CFR 261.24

(Waste Code D018 through D043) and are subject to the corrective action

regulation under 40 CFR 280 (ADEM Administrative Code 335-14-2-.01(4)(b)10 /

40 CFR 261.4(b)(10)).

• Used chlorofluorocarbon refrigerants from totally enclosed heat transfer

equipment, including mobile air conditioning systems, mobile refrigeration, and


4-2

commercial and industrial air conditioning and refrigeration systems that use

chlorofluorocarbons as the heat transfer fluid in a refrigeration cycle, provided the

refrigerant is reclaimed for further use (ADEM Administrative Code 335-14-2-

.01(4)(b)12 / 40 CFR 261.4(b)(12)).

• Used oil filters that are not terne plated, provided that they are drained of oil using

one of the regulatory-specified methods (ADEM Administrative Code 335-14-2-

.01(4)(b)13 / 40 CFR 261.4(b)(13)).

• Domestic sewage and any mixture of domestic sewage and other wastes that

passes through a sewer system to a publicly-owned treatment works for treatment

(ADEM Administrative Code 335-14-2-.01(4)(a)1 / 40 CFR 261.4(a)(1).

• Scrap metal being recycled (ADEM Administrative Code 335-14-2-.01(4)(a)13 / 40

CFR 261.4(a)(13)).

4.3 LISTED WASTES

Hazardous waste identification and classification is conducted according to the guidance

of ADEM Administrative Code 335-14-2 / 40 CFR 261. Listed wastes are wastes that have

been deemed harmful to human health and the environment. State and federal

regulations define four categories of listed wastes:

• F - List: Non-specific sources (ADEM Administrative Code 335-14-2-.04(2) / 40

CFR 261.31).

• K - List: Specific sources (ADEM Administrative Code 335-14-2-.04(3) / 40 CFR

261.32).

• P - List: Pure or commercial grade formulations of certain specific unused

chemicals that are acutely hazardous (ADEM Administrative Code 335-14-2-.04(4)

/ 40 CFR 261.33). This list also includes the listed items when they are residues

remaining in the containers, contaminated solid, water or other debris resulting

from the cleanup of a spill with the P-listed waste as the major ingredient.

• U - List: Pure or commercial grade formulations of certain specific unused

chemicals (ADEM Administrative Code 335-14-2-.04(5) / 40 CFR 261.33). This list

also includes the listed items when they are residues remaining in the containers,


4-3

contaminated solid, water or other debris resulting from the cleanup of a spill with

the U-listed waste as the major ingredient.

4.4 CHARACTERISTIC WASTES

A characteristic waste is a waste that is not excluded that exhibits one of the four

characteristics defined in 40 CFR Part 261 Subpart C - ignitability (D001), corrosivity

(D002), reactivity (D003), and toxicity (D004 - D043). The characteristic waste codes may

be applicable to wastes that are listed as described in Section 4.3 above as well as to

wastes that are not listed.

The characteristic of ignitability (Waste Code D001) is defined in ADEM Administrative

Code 335-14-2-.03(2) / 40 CFR 261.21. According to this regulation, a liquid waste is

considered ignitable when it has a flash point less than 140 degrees Fahrenheit. Some

examples commonly found in motor pools, material storage locations, and HWSAPs are

paints, paint thinners, wax removers, waste ink, M256A1 (chemical agent detection) kits,

and dry cleaning solvents. A non-liquid waste is considered ignitable when, under

standard temperature and pressure, it is capable of spontaneous and sustained

combustion, such as solvent rags or paint rags. A waste also exhibits the characteristic

of ignitability if it is an ignitable compressed gas as defined by ADEM Administrative Code

335-14-2-.03(2)(a)3 / 49 CFR 173.300 or if it is an oxidizer as defined by ADEM

Administrative Code 335-14-2-.03(2)(a)4 / 49 CFR 173.151.

The characteristic of corrosivity (Waste Code D002) is defined in ADEM Administrative

Code 335-14-2-.03(3) / 40 CFR 261.22. A waste is corrosive when it is an aqueous

solution with a pH of less than or equal to 2 or greater than or equal to 12.5. A liquid waste

is a corrosive waste when it corrodes steel at a rate greater than 1/4 inch per year at a

test temperature of 130 degrees Fahrenheit. Some examples of corrosive wastes are

nitric acid, phosphoric acid, battery acids, rust removers, etching fluids, alkaline

degreasers, lime and water mixtures, decontamination solution number 2 (DS2), and

sodium hydroxide.

The characteristic of reactivity (Waste Code D003) is defined in ADEM Administrative

Code 335-14-2-.03(4) / 40 CFR 261.23. Examples of reactive wastes are calcium

hypochlorite, flameless ration heaters (FRH) from meals-ready-to-eat (MRE), and


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unexpended military munitions. A waste is considered reactive when it meets any of the

following conditions:

• Normally unstable and readily undergoes violent change without detonating.

• Reacts violently with water.

• Forms potentially explosive mixtures with water.

• Generates toxic gases, vapors, or fumes when mixed with water.

• Is capable of detonation or explosive reaction if it is subjected to a strong initiating

source or if heated under confinement.

• Is readily capable of detonation or explosive decomposition or reaction at standard

temperature and pressure.

• Forbidden explosive as defined in 49 CFR 173.51, or a Class/Division 1.1, 1.2, or

1.3 explosive as defined in 49 CFR 173.50. Examples are nitroglycerin, super

tropical bleach (STB), and sodium metal.

The characteristic of toxicity (Waste Codes D004-D043) is defined in ADEM

Administrative Code 335-14-2-.03(5) / 40 CFR 261.24. A solid waste exhibits the

characteristics of toxicity if an extract from a representative sample of the waste contains

any of the contaminants listed in the following table at a concentration equal to or greater

than the respective value given in the table. Some examples commonly found are

insecticides, mercury batteries, cadmium, lindane, terne plated (alloy of tin and lead) oil

filters, used photo solution containing silver, lead-acid batteries, and lead-based paint

(LBP) chips.

4.5 FORT RUCKER WASTE IDENTIFICATION REQUIREMENTS

Under RCRA regulations, it is the responsibility of the organization that generates or owns

a hazardous waste to properly and accurately identify the contents of all containers

holding hazardous waste. The Hazardous Waste Program Manager is responsible for

profiling each waste stream generated at Fort Rucker. Hazardous waste will be identified

by common name, EPA hazard characteristic, and waste codes during its accumulation

at the point of generation (e.g. the HWSAP). This is generally based upon product SDS

and user knowledge of the process producing the waste, since most generators have

well-established procedures and processes that produce known waste streams. The


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waste profile may also use laboratory analysis of the waste stream. Each generator is

required to provide information on changes in waste streams as a result of a process or

chemical change to DPW-ENRD prior to implementation.


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Table 4-1 Maximum Concentration of Contaminants for the Toxicity Characteristic

EPA WASTE CODE CONTAMINANT REGULATORY LEVEL

(mg/L) D004 Arsenic 5.0 D005 Barium 100.0 D018 Benzene 0.5 D006 Cadmium 1.0 D019 Carbon tetrachloride 0.5 D020 Chlordane 0.03 D021 Chlorobenzene 100.0 D022 Chloroform 6.0 D007 Chromium 5.0 D023 o-Cresol* 200.0 D024 m-Cresol* 200.0 D025 p-Cresol* 200.0 D026 Total Cresol* 200.0 D016 2,4-D 10.0 D027 1,4-Dichlorobenzene 7.5 D028 1,2-Dichloroethane 0.5 D029 1,1-Dichloroethylene 0.7 D030 2,4-Dichlorotoluene 0.13 D012 Endrin 0.02 D031 Heptachlor (and its epoxide) 0.008 D032 Hexachlorobenzene 0.13 D033 Hexachlorobutadiene 0.5 D034 Hexachloromethane 3.0 D008 Lead 5.0 D013 Lindane 0.4 D009 Mercury 0.2 D014 Methoxychlor 10.0 D035 Methyl ethyl ketone 200.0 D036 Nitrobenzene 2.0 D037 Pentachlorophenol 100.0 D038 Pyridine 5.0 D010 Selenium 1.0 D011 Silver 5.0 D039 Tetrachloroethylene 0.7 D015 Toxaphene 0.5 D040 Trichloroethylene 0.5 D041 2,4,5-Trichlorophenol 400.0 D042 2,4,6-Trichlorophenol 2.0 D017 2,4,5-TP (Silver) 1.0 D043 Vinyl chloride 0.2

SECTION FIVE Hazardous Waste Satellite Accumulation Points

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Section 5 Hazardous Waste Satellite Accumulation Points

5.1 GENERAL

A HWSAP is a point of generation at which a maximum of 55-gallons of hazardous waste

or one quart of acutely hazardous waste is accumulated over an indefinite period of time

and is controlled by the operator generating the waste. The 55-gallon limit applies to the

total of all the non-acutely hazardous waste accumulated at a HWSAP. In accordance

with the ADEM interpretation letter dated 26 April 2005, each waste stream from a

generating process may be considered a separate HWSAP even if they are located in the

same area if they are managed in accordance with regulatory guidelines (see Section 5.3

below for additional details). A copy of this letter is included in Appendix F.

Generators in a shop, laboratory, or other work area where small amounts of waste are

produced generally use this type of accumulation area. Each HWSAP must be located at

or near the area where the waste is generated and must be under the direct control of the

organization generating the waste.

Fort Rucker has approximately 75 HWSAPs located throughout the installation. Based on

organization missions, HWSAPs may change due to deployments or other factors. DPW-

ENRD tracks the establishment and closure of HWSAPs. The Hazardous Waste Program

Manager maintains a list of the HWSAPs.

5.2 HWSAP MANAGERS

A HWSAP manager and an alternate manager shall be formally assigned/appointed to

maintain the area in accordance with the requirements of this section using USAACE

Form 2733, HWSAP and HWAS Manager Appointment Memo, a copy of which is located

in Appendix D. These HWSAP Managers must receive documented training for

familiarization of this plan, the chemicals they will be working with and applicable RCRA

regulations.

See Section 3.5 for responsibilities of the HWSAP managers.


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5.3 WASTE ACCUMULATION QUANTITIES

A generator may accumulate up to 55-gallons of hazardous waste or one quart of acutely

hazardous waste in a HWSAP at or near any point of generation where wastes initially

accumulate and must be under the control of the operator generating the waste.

Neither the regulations nor the preamble to the regulations expressly defines the terms

“at or near the point of generation” or “under the control of the operator” with reference to

the distance from the point of generation or the level of control required. Therefore, DPW-

ENRD can evaluate each situation on a case-by-case basis in order to determine if a

storage area qualifies as a satellite accumulation area.

ADEM has determined that it is permissible to have adjacent HWSAPs provided that

a. Each HWSAP is for a separate waste stream.

b. The HWSAP sign clearly identifies each separate waste stream (i.e., one waste

stream for solid paint filters and one waste stream for liquid paint wastes).

c. Each waste stream does not exceed the 55-gallon or 1-quart limit.

d. Each container is labeled with the words "Hazardous Waste" or with other words

that identify the contents of the containers in accordance with ADEM

Administrative Code 335-14-3-.03(5)(c)(ii) / 40 CFR 262.34(c).

e. Incompatible wastes are stored separately.

When a generator accumulates more than 55-gallons of hazardous waste or one-quart of

acutely hazardous waste, personnel should mark the container with the date on which the

threshold is exceeded and remove the container within three consecutive days to the 90-

HWAS.

Fort Rucker uses interim containers for collecting hazardous waste in many work areas.

These containers will meet all requirements for managing a HWSAP with the exception

of weekly inspections. ADEM does not limit the use of white step cans to a certain area

or shop, or access to a certain HWSAP, but rather to the obeying of HWSAP rules at each

location. Section 5.4 contains information about container management requirements,

including these interim containers. Additional details are available in the ADEM


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correspondence dated April 25, 2005 regarding clarifications of installation HWSAP

requirements. A copy of the ADEM correspondence is included in Appendix F.

5.4 CONTAINER MANAGEMENT REQUIREMENTS

5.4.1 Compatibility Only containers approved by DPW-ENRD may be used to accumulate hazardous wastes.

Wastes are only stored in containers compatible with waste materials. Incompatible

wastes must not be consolidated and collected in the same container. Only compatible

wastes will be stored together. In summary, these compatibility guidelines are followed:

• Segregate reactive wastes from ignitable wastes.

• Segregate acids from caustics.

• Segregate corrosives from flammables.

• Segregate oxidizers from all other wastes.

5.4.2 General Requirements The following general requirements should be implemented in all HWSAPs:

1. All containers must be maintained in good condition with no dents, corrosion,

leaks, noticeable spills, or bulging. If a container leaks, waste should be transferred

to another container or overpacked.

2. Containers must be stored in a manner such as to avoid direct contact with the

foundation or flooring by the use of pallets or other suitable device to facilitate

inspections.

3. Containers of highly flammable wastes must be properly grounded.

4. If the accumulation area is enclosed, adequate ventilation and lighting must be

provided.

5. If the accumulation area is not enclosed, it must be protected from direct sunlight

and inclement weather.

6. Waste containers must be closed at all times, except when it is necessary to add

or remove waste from the container. If a container with a funnel or funnel device

(securely attached and consistently used) is to be considered a “closed container,”

the funnel must have a lid equipped with a seal (ball valve) and latching/locking

mechanism to secure it when waste is not being poured or added to the container.


5-4

7. Sufficient aisle space must be maintained in accumulation areas to allow for the

unobstructed movement of personnel, fire protection equipment, spill control

equipment, and decontamination equipment.

5.4.3 Liquid Waste Container Requirements A means of secondary containment (for the entire volume of the container) must be used

for liquids such as placement of containers in appropriately sized containment pallets,

drip pans, or impermeable berms. Liquid wastes should be containerized in closed top

drums equipped with a bung rather than an open top drum to minimize the potential for

accidental spills and releases.

5.4.4 Labels and Signs Hazardous waste containers must be marked clearly with the words "HAZARDOUS

WASTE", a description of the contents, the hazardous waste code(s), and the EPA ID

number.

Each HWSAP will be posted with a sign with the words "Hazardous Waste Satellite

Accumulation Point". It is required that the HWSAP Manager’s and Alternate HWSAP

Manager’s name and contact telephone number/extension information also be included

on this sign.

5.4.5 Interim Container Management A single HWSAP may have multiple points of generation. Generators may transfer

hazardous waste between rooms within a single building and/or containers to facilitate

proper management. Fort Rucker has implemented a process in which interim HWSAPs

are used in work areas for accumulating waste during operations. These interim HWSAPs

are primarily used for accumulated rags and other absorbent materials at individual work

stations. These containers must meet all regulatory requirements for a HWSAP, but they

are required to be emptied at the end of each shift into a consolidated HWSAP with

additional management requirements (i.e., weekly inspections).

5.5 SECURITY

HWSAPs usually consist of one container stored within operational areas in compliance

with the requirement to be at or near the point of generation. These operational areas are


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located within secure facilities, such as motorpools, hangars, or buildings, which have

provisions for security to prevent entry by unauthorized personnel. All entrances will be

locked when facilities are not occupied. Signs and labels will include the words

“HAZARDOUS WASTE” as specified in Section 5.4.4. Also, Fort Rucker is considered a

secure installation, which prevents unauthorized access to these facilities.

5.6 SPILL PREVENTION AND RESPONSE

Each HWSAP storing a liquid waste is required to have an impervious spill containment

system with sufficient capacity for containers (ability to contain 10 percent of the total

volume of all containers or the volume of the largest container, whichever is greater).

Lined or unlined sandbag dikes and asphalt pavements are not acceptable unless a berm

is constructed in a manner which would prevent migration of a spill or leak.

HWSAPs will not be located near storm drains, sewer drains, or washracks. Washracks

with oil/water separators do not serve as secondary containment and should not be used

in this manner. Oil/water separators are designed to capture oil residue but not spills.

HWSAPs will be located in areas protected from the elements and in facilities that do not

allow rainwater to collect. If rainwater has collected, organizations will visually inspect the

water for signs of contamination. If the rainwater is contaminated, organizations will

contact DPW-ENRD for guidance about handling and disposing of this water. Otherwise,

organizations will discharge the water in accordance with established procedures. Fort

Rucker Form USAACE Form 2716, Secondary Containment Draining Activity Log

(Appendix G), will be maintained for each release of water from the HWSAP to show that

it was visually inspected for contamination prior to discharge.

Each HWSAP will develop a Site Specific Spill Plan utilizing USAACE Form 2719, Site

Specific Spill Plan. If requested, a copy of the Site Specific Spill Plan will also be submitted

to the Fire Department.

Basic fire, spill and safety equipment will be provided for each HWSAP. Equipment will

include, at a minimum, a fire extinguisher appropriate for the waste being accumulated

and spill cleanup material such as absorbent rolls or pads. This equipment shall be

located in the immediate area and be readily accessible to personnel in case of a spill or


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fire. All personnel involved with the HWSAPs shall be trained in the proper use of fire

equipment and spill material as well as the hazards associated with the waste.

HWSAP managers will ensure that all containers are closed, not leaking, and all spills or

releases are properly cleaned up and reported. Adequate spill control and containment

material must be on hand (within 50 feet of the HWSAP) to contain and clean up minor

spills. Upon discovery of a spill, personnel will attempt to stop the source of the spill, if

safe to do so, and notify the immediate supervisor or the Fort Rucker Fire Department at

911 if the supervisor is not available. All spills or releases must be cleaned up

immediately, with consideration for safety. The immediate area of the spill will be

evacuated to facilitate cleanup activities. Personnel will always use appropriate PPE.

The Fort Rucker Fire Department is the Installation On-Scene Commander at spill sites

until the emergency situation is secured and the situation is deemed safe for non-

emergency personnel to enter the spill control zone. DPW-ENRD then assumes control

of the spill site and coordinates spill cleanup. If contract help is required, DPW-ENRD

starts the contract mechanism process and requires reimbursement from the organization

involved. All organizations – including military, contractors, and civilians – and their

supervisors are financially and legally responsible for the cleanup of spills within their

areas.

5.7 INSPECTIONS

The HWSAP must be inspected weekly (every 7 days) using USAACE Form 2725,

HWSAP Inspection Checklist, located in Appendix E. If inspections reveal any

noncompliance, immediate action is taken to correct the deficiencies. Copies of all

inspections are kept for a minimum of three years. Inspections must be conducted by

someone who has attended the HWSAP Manager course provided by DPW-ENRD, which

is described in Section 5.8 below.

DPW-ENRD conducts environmental compliance inspections of all active hazardous

waste generation sites quarterly. These inspections are recorded on Fort Rucker Form

USAACE Form 2717, Environmental Compliance Inspection Checklist (Appendix E).

Additional assistance visits are performed on an as-needed or requested basis. DPW-

ENRD provides guidance to the organization for correcting deficiencies and conducts


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follow-up inspections to ensure that deficiencies have been corrected. DPW-ENRD

reports the inspection results through the chain of command and assists installation

organizations with specific guidance required to obtain necessary training.

5.8 TRAINING

Training is required for personnel who handle hazardous waste and for managers and

supervisors of personnel, who handle hazardous waste, including those who maintain

and operate the HWSAPs in their shops and work areas (HWSAP Managers).

Initial personnel training shall begin within 60 days and be completed within six months

of the individual being assigned to hazardous waste handling duties. Training may consist

of formal classroom instruction, informal training (e.g., meetings, seminars, etc.), and/or

on-the-job training. Personnel trained in hazardous waste management procedures must

provide the training. At a minimum, the training program shall meet EPA and ADEM

regulatory requirements.

Training will focus on how to safely manage and operate a HWSAP. It must enable

employees involved with hazardous waste operations to perform their duties without

endangering themselves or other employees. Emphasis should be given to the

emergency response, use of protective equipment and clothing, recognition of hazardous

waste, hazards of waste encountered, and an overview of RCRA regulations as they

relate to employees.

DPW-ENRD offers a two hour HWSAP Manager Course that is required annually for all

personnel assigned as a primary or alternate HWSAP manager. This course meets all

regulatory requirements for training. Course offerings are listed on the Sustainable Fort

Rucker website (https://www.fortrucker-env.com).

All training will be documented and kept on file for three years from the date the employee

last worked at the organization/facility. Copies of annual Fort Rucker training certificates,

individual job descriptions, and training forms will be kept at each site that operates a

HWSAP. Organizations should use USAACE Form 2735, Hazardous Waste Job

Description and Training Record, to document training related to hazardous waste

specific for their job responsibilities. This form is not required if the organization has an

https://www.fortrucker-env.com/


5-8

equivalent method for tracking their training, such as a database, that includes a job

description and information on the training received. The Hazardous Waste Program

Manager will make the determination as to whether the documentation is equivalent to

USAACE Form 2735. Approval of the usage of a different form must be in writing and

kept on file with the training records.

5.9 RECORDKEEPING

Individual activities and tenants will maintain the following records and documents and

maintain them in accordance with EMS-P008, Records Management Procedure, and

EMS-P002, Document Control Procedure:

5.9.1 Records that must be kept in the HWSAP a. Site Specific Spill Plan (USAACE Form 2719) first page with the location of the

entire plan noted

b. HWSAP inspection records (USAACE Form 2725)

5.9.2 Records that may be kept in a separate work area a. Complete Site Specific Spill Plan (USAACE Form 2719)

b. Fort Rucker HWMP (this document)

c. Hazardous waste training records, including USAACE Form 2735 (maintain for a

minimum of three years from when the employee last worked at the facility)

d. Fort Rucker ISCP and SPCC Plan

SECTION SIX Hazardous Waste Accumulation Sites

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Section 6 Hazardous Waste Accumulation Sites

6.1 HAZARDOUS WASTE ACCUMULATION SITES

Each 90-HWAS is a temporary, non-permitted collection area where hazardous waste is

stored for less than 90-days (less than 180-days for a small quantity generator) pending

transfer to a permitted facility. This type of accumulation area may be used to store any

amount of hazardous waste from one or more HWSAPs, or it may serve a location where

an amount of hazardous waste over 55 gallons (or one quart acute hazardous waste) is

generated on a regular basis. The date of waste generation (accumulation start date) will

be the date that any amount of hazardous waste is first accumulated at the 90-HWAS

and shall be clearly marked and visible for inspection on each container.

Fort Rucker has five 90-HWAS, which are located at building 1207 (main 90-day HWAS),

Lowe, Hanchey, Cairns, and near building 1001 (the Aviation Maintenance Support Shop

[AMSS]). Shell has a 180-day HWAS, which is managed in the same manner as a 90-

HWAS.

The following criteria are followed when managing a 90-HWAS.

6.2 WASTE ACCUMULATION

Hazardous waste may accumulate at a 90-HWAS for no more than 90 days from the

accumulation start date. Once a container from a HWSAP has been transferred from a

HWSAP to a 90-HWAS, the site manager has up to 90 days from the accumulation start

date to arrange transfer to a permitted storage site. All waste should be turned in to the

main 90-day site within two weeks of transfer from the HWSAP, except waste generated

at Cairns and Shell. The main 90-HWAS is open every Thursday for turn in from 0900 to

1130 with no appointment required. Appointments may be scheduled for other times by

contacting the HMCC.

Organizations must turn in a completed DD Form 1348-1A, Issue Release/Receipt

Document, (Appendix H) with each waste turn in. Instructions on how to fill out the DD

1348-1A are included in EMS-WI-SW001 Waste Turn-In Procedure, which can be found

in Appendix K. Copies of the turn-in documentation will be kept for a minimum of three

years.


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6.3 SIGNAGE

Signs identifying the area as a 90-HWAS, the hazards, and emergency contact

information must be conspicuously posted. Signs will be posted in container accumulation

sites that say: “HAZARDOUS WASTE ACCUMULATION POINT – AUTHORIZED

PERSONNEL ONLY” and “NO SMOKING WITHIN 50 FEET.” Signs must be visible from

all sides of the accumulation site and must be legible from a distance of at least 25 feet.

6.4 FACILITY SPECIFICATIONS

Each 90-HWAS is designed, constructed, maintained, and operated to minimize the

possibility of fire, explosion, or any unplanned sudden or non-sudden release of

hazardous waste or hazardous waste constituents to air, soil, or surface water that could

threaten human health or the environment. Container storage areas at each 90-HWAS

are protected from the elements, either in a covered area, inside the working area, or in

a separate building. If the 90-HWAS is located indoors, it will have adequate ventilation

provided. All 90-HWAS will have adequate lighting. All 90-HWAS are located in facilities

that minimize the potential for rainwater to collect. However, if rainwater is collected, the

Hazardous Waste Program Manager will evaluate the collected water in order to

determine the proper method of disposal.

Container storage areas shall have a containment system that is capable of collecting

and holding spills, leaks, and precipitation. Run-on of precipitation into the containment

system shall be prevented. Spilled or leaked waste and accumulated precipitation shall

be removed from the sump or collection area in as timely a manner as is necessary to

prevent overflow of the collection system. Acceptable containment systems include, as

applicable:

a. A sufficiently impervious underlying base for the containers, free of cracks or gaps,

to contain leaks, spills, and accumulated rainfall until the collected material is

detected and removed;

b. Efficient drainage design, so that standing liquid does not remain on the base

longer than one hour after a leakage or precipitation event, unless the containers

are elevated, or are in some other manner protected from contact with

accumulated liquids; and


6-3

c. Capacity sufficient to contain 10 percent of the total volume of all containers or the

volume of the largest container, whichever is greater.

Storage areas that store containers holding only non-liquid wastes need not have a

containment system provided that the storage area is sloped or otherwise designed and

operated to drain and remove liquid resulting from precipitation; or the containers are

elevated or are otherwise protected from contact with accumulated liquid.

Each 90-HWAS is provided with necessary communication equipment, including a

handheld two-way radio or accessible telephone. Fire control equipment appropriate for

the waste being accumulated must be located within 50 feet of the accumulation site.

Sufficient aisle space will be maintained in accumulation areas to allow for the

unobstructed movement of personnel, fire protection equipment, spill control equipment,

and decontamination equipment. Equipment will not be stored or parked in a manner that

would prohibit access to containers.

6.5 CONTAINER MANAGEMENT REQUIREMENTS

All wastes must be stored in accordance with ADEM Administrative Code 335-14-6-.09 /

40 CFR 265 Subpart I – Use and Management of Containers. The following specific

management procedures are followed at each of the 90-HWAS.

6.5.1 Container Stacking Containers that are 30-gallon or more will not be stacked more than two high. This

requirement applies to all containers, including cardboard boxes.

6.5.2 Container Specifications In general, only Department of Transportation/United Nations (DOT/UN) containers will

be used to accumulate hazardous wastes. All containers will be maintained in good

condition with no dents, corrosion, leaks, noticeable spills, or bulging. Containers must

be stored so as to avoid direct contact with the foundation or flooring by the use of pallets

or other suitable device to facilitate inspections.

Containers of ignitable or reactive waste will be located at least 50 feet from the

installation property line. Only non-sparking tools will be used when personnel are

working with containers that hold an ignitable waste. When transferring ignitable wastes


6-4

between containers, personnel will ensure that both containers are bonded to one another

and that both containers are properly grounded.

Containers must not be overfilled. In accordance with DOT requirements, liquid wastes

should only be stored in bung-type drums or cans. In order to allow for expansion of liquid

wastes resulting from temperature fluctuations and to prevent overflowing, the following

headspace guidelines are recommended:

• 55-gallon drum should have 3 to 4 inches of headspace

• 5-gallon cans should have 1.5 to 2 inches of headspace

• 1-gallon cans should have 1 inch of headspace

Containers must be closed at all times, except when it is necessary to add or remove

waste from the container. In general, waste should not be added to containers in the 90-

HWAS.

6.5.3 Waste and Container Compatibility Wastes must only be stored in containers compatible with waste materials. Hazardous

wastes shall be stored in containers that are chemically compatible with the waste. This

means that the containers used shall be made of or lined with materials that are non-

reactive with the hazardous waste to be stored, so that the integrity of the containers to

contain the waste is not compromised. For example, corrosive acids must not be placed

into a steel drum. Hazardous waste may not be placed in an unwashed container that

previously held an incompatible waste or material.

Incompatible wastes will not be consolidated and collected in the same container. Only

compatible materials will be stored together. Incompatible wastes should be physically

separated with different containment structures and as far apart as practical. A storage

container holding a hazardous waste that is incompatible with any waste or other

materials stored nearby in other containers shall be separated from the other materials or

protected from them by means of a dike, berm, wall, or other device. In summary, these

compatibility guidelines will be followed:

• Segregate reactive wastes from ignitable wastes

• Segregate acids from caustics


6-5

• Segregate corrosives from flammables

• Segregate oxidizers from all other wastes

6.5.4 Damaged Containers Hazardous wastes containers that are found to be leaking, corroded, or otherwise

deteriorated must be either transferred to a different container or over packed in DOT-

approved containers at any time during storage and prior to being turned in for disposal.

The over-pack container must be durable, non-leaking, compatible, and constructed to

safely contain the material being placed in it.

When using over-pack containers, ensure that an appropriate container is used in order

to prevent accident, personal injury, or costly cleanup of spills. Over-pack containers must

be marked and labeled the same way as any other container of hazardous waste.

6.5.5 Container Labeling In accordance with ADEM Administrative Code 335-14-3-.03(5)(a)2 and 3 / 40 CFR

262.34(a)(2) and (3), containers must be marked with the accumulation start date, the

EPA hazardous waste number, and with the words “HAZARDOUS WASTE.” Labels or

markings must be easily visible for inspection. In addition to the above requirements, the

following information should be included on the hazardous waste label that is affixed prior

to transportation for disposal, in accordance with ADEM Administrative Code 335-14-3-

.03(3)(b) / 49 CFR 172.304 requirements for marking containers:

• “HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found,

contact the nearest police or public safety authority or the U.S. Environmental

Protection Agency.”

• Generator's Name and Address

• Generator's EPA ID number

• Manifest Tracking Number

Each container will also be labeled in accordance with the requirements found in 49 CFR

172.400. Appendix I contains an excerpt of this regulation with the necessary table for

identifying required labels for each hazard class. The hazardous materials table in 49


6-6

CFR 172.101 lists the required labels for each hazardous substance that may be

transported.

A waste profile must be available for all hazardous wastes at the facility. The accumulation

start date will be marked on each container. If the waste comes from a HWSAP, the date

on the container is the date that the container was filled at the HWSAP prior to transfer to

the 90-HWAS. If waste is added to a new container at the 90-HWAS, the accumulation

start date is the date the first amount of waste was added to the container. If waste from

separate containers is combined, the accumulation state date will be the date for the

oldest waste that was combined.

Any drum with unknown contents must be marked “PENDING ANALYSIS” and the date

DPW-ENRD obtained a sample. When the analytical results are received, a waste profile

will be completed, and the container will be labeled appropriately. The accumulation start

date will be the date the sample was obtained. Records of any test results, waste

analyses, and waste determinations will be maintained for three years.

6.6 SECURITY

Each 90-HWAS is located within a secure area. All entrances will be locked when the

facilities are closed. Signs are posted with the wording “DANGER – UNAUTHORIZED

PERSONNEL KEEP OUT” at the entrance to each area. Signs are also posted with the

wording “HAZARDOUS WASTE AREA” and “NO SMOKING” where the hazardous waste

is actually stored. All signs should be legible from 25 feet away.

6.7 SPILL PREVENTION AND RESPONSE

The container accumulation areas at the 90-HWAS must have impervious containment

systems with sufficient capacity to contain 10 percent of the total volume of all containers

or the volume of the largest container, whichever is greater.

90-HWAS is required to have a Site Specific Spill Plan. As discussed in the ISCP,

USAACE Form 2719, Site Specific Spill Plan is required to be utilized. The first page of

USAACE Form 2719, Site Specific Spill Plan must be posted in a prominent place

adjacent to each 90-HWAS. The remainder of the plan must be placed in the location


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designated on page 1 of the form so that everyone involved in working at the site can

access and implement its contents.

Adequate spill control and containment materials will be stored within 50 feet of

accumulation sites to contain and clean up minor spills. All spills or releases will be

cleaned up immediately or as soon as it is safe to clean up the spill. All spill cleanup

materials will be disposed properly.

6.8 INSPECTIONS

Each 90-HWAS and its containers must be inspected weekly and each time waste is

placed in or removed from the site (see Appendix E for an inspection form, USAACE

Form 2726, HW 90-Day Accumulation Site Inspection Log). The site manager or other

individual performing the inspection will look for spills and leaks and for deterioration of

containers and the containment system. The inspector shall also check the accumulation

date on each container to ensure that no container holding hazardous waste is nearing

the 90-day limit. DPW-ENRD must be notified immediately if any container in the 90-day

site exceeds 60 days from the accumulation start date on the label. The inspection record

shall show the date of inspection, inspector's name, deficiencies noted, and corrective

actions implemented. The record containing this information will be maintained as

indicated in Section 6.10 Recordkeeping.

6.9 TRAINING

Training is required for personnel who handle hazardous waste and for managers and

supervisors of personnel who handle hazardous waste, including those who maintain and

operate the 90-HWAS.

Initial training will be completed within six months of designation. All employees must be

directly supervised until training is completed. Training consists of formal classroom

instruction, informal training (e.g., meetings, seminars, workshops, etc.), and on-the-job

training. Training records must be maintained on-site for a minimum of three years.

An annual review of the training is required not later than 365 days from the date of the

initial training session or prior annual training. Training records must be maintained on-

site for a minimum of three years.


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Personnel trained in hazardous waste management procedures must provide the training.

At a minimum, the training program shall meet EPA and ADEM regulatory requirements.

Training will focus on how to safely manage and operate a RCRA hazardous waste

accumulation area. It must enable employees involved with hazardous waste operations

to perform their duties without endangering themselves or other employees. Emphasis

should be given to emergency response, use of protective equipment and clothing,

recognition of hazardous waste, hazards of the waste, and an overview of RCRA

regulations as they relate to employees.

The DOD Hazardous Materials and Hazardous Waste Handlers Course is taught each

year to meet these training requirements. The initial 24-hour course and the annual 8-

hour refresher course are required for all 90-HWAS Managers. DPW-ENRD also presents

a 90-HWAS Manager Course periodically that provides two hours of additional training to

address specific inspection, handling, and labeling requirements for the installation.

Organizations should use USAACE Form 2735, Hazardous Waste Job Description and

Training Record, to document training related to hazardous waste specific for their job

responsibilities. This form is not required if the organization has an equivalent method for

tracking their training, such as a database, that includes a job description and information

on the training received. The Hazardous Waste Program Manager will make the

determination as to whether the documentation is equivalent to USAACE Form 2735.

Approval of the usage of a different form must be in writing and kept on file with the

training records.

6.10 RECORDKEEPING



EMSP002, Document Control Procedure:

6.10.1 Records that must be kept in the 90-HWAS a. Site Specific Spill Plan (USAACE Form 2719)

b. 90-HWAS inspection records (USAACE Form 2726)


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6.10.2 Records that may be kept in a separate work area a. Hazardous waste training records, including USAACE Form 2735 (maintain for a

minimum of three years from when the employee last worked at the facility)

b. Fort Rucker HWMP (this document)

c. Fort Rucker ISCP and SPCC Plan

d. DD Form 1348-1A turn-in documents

e. Manifests and Land Disposal Restrictions (Cairns, Shell, and Main 90-Day only)

f. Hazardous waste profile list


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SECTION SEVEN Hazardous Waste Disposal Procedures

7-1

Section 7 Hazardous Waste Disposal Procedures

7.1 GENERAL

DLADS is the primary method of disposal for hazardous waste generated by

organizations and activities on Fort Rucker. Alternate means of disposal may be used at

the discretion of the Hazardous Waste Program Manager. All hazardous waste disposed

through DLADS must be accomplished as quickly as possible to minimize liability for

environmental violations or spills.

Contractors that are not part of the normal operations of Fort Rucker, such as Corps of

Engineers construction contractors, should coordinate with DPW-ENRD prior to starting

work to ensure that procedures for hazardous waste disposal are established. In general,

these contractors will arrange for hazardous waste disposal separately from existing

installation hazardous waste contracts. Shipments of hazardous waste off-site must be

under the Fort Rucker EPA ID number, and all manifests will be signed by an authorized

representative in DPW-ENRD when the waste is not shipped through DLADS. EMS-WI-

SW010, Contractor Hazardous Waste Management, contains additional details about the

process that contractors should follow for properly managing their waste. A copy of this

work instruction is located in Appendix J.

7.2 HAZARDOUS MATERIAL REUSE EVALUATION

Much of the hazardous waste that is disposed each year is composed of unused

hazardous materials. In an effort to minimize the waste that is generated from unused

items, Fort Rucker has implemented a hazardous material reuse program. The process

is described below.

When an organization wishes to discard excess hazardous materials which are unopened

and/or are in good condition, the organization should bring the items to the HMCC (Bldg

1315) for evaluation. If possible, items will be added to the HMCC inventory, and

hazardous waste costs and liability will be avoided. Items with expired shelf life will be

researched by HMCC personnel and extended when possible.

7.3 PREPARATION FOR DISPOSAL AND PACKAGING

ADEM rule 335-14-3-.03 states that before transporting hazardous waste or offering

hazardous waste for transportation off-site, a generator must package the waste in


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accordance with the applicable U.S. DOT regulations on packaging under 49 CFR Parts

173, 178, and 179. For this reason, DPW-ENRD recommends storing waste at all

accumulation and storage sites on Fort Rucker in DOT-approved containers.

7.4 HAZARDOUS WASTE TURN IN PROCEDURES

Activities that generate hazardous waste and maintain HWSAPs will establish procedures

to ensure that all hazardous waste is turned in to a 90-HWAS within three days of the

date that the 55-gallon limit (or 1-quart of acutely hazardous waste limit) is reached. Both

the label and the turn-in document must accurately represent the contents of the

container.

The EMS Work Instruction (EMS-WI-SW001 Waste Turn-In Procedure) for hazardous

waste turn-in is provided in Appendix K. It specifies that activities must complete a DD

Form 1348-1A and have an active and approved Hazardous Waste Profile on file with

DPW-ENRD for each hazardous waste item to be turned in. Instructions on how to fill out

the DD 1348-1A are included in EMS-WI-SW001 with specific requirements of the Fort

Rucker 90-HWAS turn-in procedures.

Centralized 90-HWAS personnel will receive the waste, ensure that it is correctly labeled

and identified, and store it until it is picked-up by waste transport contractors. Waste that

is not properly labeled and identified or that is not properly packaged and safe to handle

will not be accepted at the accumulation area. Arrangements will have to be made by the

generating organization to immediately correct any situation that results in non-

acceptance of the hazardous waste at the 90-HWAS.

7.5 WASTE PROFILES

All wastes that are disposed through DLADS must have a waste profile completed to

characterize the waste. DPW-ENRD will prepare Hazardous Waste Profiles (Appendix L) using information gathered from SDS, analyses, or user process knowledge. Required

information includes generator name; USEPA ID and State ID; facility address; technical

contact’s name, title and telephone number; name of waste; waste code(s) (when

necessary); material characterization information (optional); RCRA characteristic

information; chemical composition information; material composition; shipping


7-3

information; generator certification; toxicity characteristic information; hazardous waste or

non-RCRA identification; and DLADS verification information. Profiles will be created and

are stored electronically on the DPW-ENRD shared drive and in hardcopy.

When a new unprofiled waste is to be disposed, the SDS, any user knowledge, and any

additional information about the waste will be forwarded to DPW-ENRD. If waste

ingredients or chemical properties are unknown, items will be characterized prior to

disposal by DPW-ENRD. See Section 9 for information about Fort Rucker’s Hazardous

Waste Analysis Plan. At the time hazardous waste is placed in the 90-HWAS, the

organization will coordinate with DPW-ENRD to ensure waste containers are properly

labeled and meet any other packaging requirements. If an established waste stream

changes, DPW-ENRD will notify DLADS before shipping to ensure that the disposal

facility has the most updated information on the waste stream.

7.6 HAZARDOUS WASTE MARKING AND LABELING REQUIREMENTS

7.6.1 General Requirements State and Federal regulations have established specific labeling and marking

requirements for hazardous waste containers, which cross-reference the DOT regulations

contained in 49 CFR 172. All activities that generate hazardous waste at Fort Rucker will

comply with these requirements by accumulating hazardous wastes in appropriately

labeled and marked containers. The purpose of this is to facilitate the transport of waste

from generation/accumulation sites to the 90-HWAS and to facilitate subsequent

shipment for offsite disposal. The marking and labeling requirements of RCRA and DOT

regulations will, therefore, apply to all generators and shall be accomplished as described

in the following paragraphs.

• All labels shall be filled out using permanent ink that is not water-soluble and will

not readily fade. This helps to ensure that the information will not be inadvertently

smudged or otherwise rendered illegible resulting in personal injury or costly

analyses to re-identify the waste.

• A DOT Hazard Class Label such as "flammable", "corrosive," or "oxidizer," must

be applied to the container, when appropriate, if the container is being prepared

for shipment by a hazardous waste transporter. The DLADS contractor will apply


7-4

these DOT labels prior to shipment; however, these labels are not required for

containers in a HWSAP or 90-HWAS.

• Old labels and markings should be removed or painted over to ensure that there

is no confusion about the contents. New labels should not be placed over old ones.

7.6.2 Marking ADEM Rule 335-14-03(3) indicates that hazardous waste containers should be marked

in accordance with information in the DOT Hazardous Materials Transportation

regulations of 49 CFR 172. The labeling and marking standards require that hazardous

waste be marked in accordance with the DOT Hazardous Materials Table 49 CFR

172.101. This table sets out the proper shipping name, hazard class, ID number, packing

group, and other information that must be contained on DOT shipping papers for all

hazardous wastes. Steps outlined below give information necessary in order to comply

with DOT and additional ADEM 335-14-3 requirements. Regulations require that a

generator must mark each container of 110 gallons or less specifically in accordance with

the following requirements before waste is transported. The hazardous waste disposal

contractor combines like wastes and marks containers in accordance with DOT

regulations before waste is shipped off the installation per requirements below.

a. The marking must be durable, in English, and printed on or affixed to the surface

of a package or on a label, tag, or sign.

b. The marking must be displayed on a background of sharply contrasting color.

c. The marking must be unobscured by other labels or attachments and must be

located away from other marking that could substantially reduce its effectiveness.

d. In addition, RCRA regulations require that marking include the following statement:

i) HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found,

contact the nearest police or public safety authority or the U.S. EPA.

ii) Generators Name and Address ________________________

iii) Manifest Document Number ________________________

e. For 90-HWAS, hazardous waste labeling information must be placed on the

container as soon as the first hazardous waste is placed in it. HWSAPs do not put

a date on the waste until the containers reach 55-gallons for regular hazardous

waste and one quart for acutely hazardous waste. The HWSAP manager will


7-5

ensure that waste is turned in to the 90-HWAS within three consecutive days of

the date being placed on the hazardous waste label.

f. The site manager will ensure that the date upon which each period of accumulation

begins is clearly marked and visible for inspection on each container.

g. The information required by the preceding paragraphs is generally affixed to

containers storing hazardous waste by means of a label, which may have some of

the information required by item d above preprinted. This type of form label should

not be confused with, and is in addition to, the labeling requirements of Subsection

8.6.3 below. Appendix M provides several examples of container labels for

common Fort Rucker materials. Activities generating hazardous waste may obtain

these labels through the procurement system; however, in emergencies a limited

number of labels may be obtained by contacting DPW-ENRD.

7.6.3 Labeling Prior to shipment, each container must be labeled with a Hazard Class Label (i.e.,

flammable, corrosive, oxidizer) in accordance with the applicable RCRA (ADEM Rule

335-14-3-.03(2)) and cross-referenced DOT (49 CFR 172.400) regulations on hazardous

materials.

Hazard class labels are intended to provide identification of particular hazardous

properties of the material through pictorial representation. Labels are required by RCRA

on hazardous waste containers that will be shipped off-site. However, the DLADS

contractor will apply all necessary labels prior to shipment, and the DOT labels are not

required on wastes that are being accumulated in a HWSAP or 90-HWAS.

7.7 TURN-IN DOCUMENTATION

DPW-ENRD will ensure that turn in documentation (DD Form 1348-1A, Issue

Release/Receipt Document) required for disposal of hazardous waste through DLADS is

completed. Customers will generate the DD Form 1348-1A, Issue Release/Receipt

Document (Appendix H), for turn-in to HMCC or DPW-ENRD Hazardous Waste Program

Manager and for tracking purposes. See EMS-WI-SW001, Waste Turn-In Procedure for

details (Appendix K).


7-6

7.8 TRANSPORTATION OF HAZARDOUS WASTE

Off-post transportation of hazardous waste by any installation organization is strictly

forbidden. By state and federal regulations, Cairns and Shell Airfields are considered off-

post.

On-post transportation of hazardous wastes by generating activities shall be

accomplished in strict accordance with the following procedures: Vehicles used to

transport hazardous waste must meet the motor vehicle requirements of Army Regulation

385-10, Chapter 11-3, Motor Vehicle Safety Standards.

Hazardous wastes generated at Fort Rucker may be transported on post by the

generating organization from the generation point to a 90-HWAS. Generating activities

will establish control regarding personnel permitted to transport hazardous waste. These

controls should, at a minimum, require that all personnel involved with hazardous waste

transportation be trained in accordance with the requirements of Section 2.6 of this

document. Hazardous waste should not be transported from the generation point to a 90-

HWAS by forklift unless another transportation method is not feasible.

The following procedures should be followed for transferring containers from HWSAP to

90-HWAS:

a. Generating activities are responsible for arranging the loading and transportation

of hazardous waste using in-house support elements. If the organization does not

have the capability of transporting waste to a 90-HWAS from the HWSAP, DPW-

ENRD will provide pick-up assistance on a case-by-case basis.

b. Hazardous waste containers shall be secured during transportation in order to

avoid spills.

c. 55-gallon drums will be transported no more than one layer of three to a pallet to

ensure a stable load and avoid tipping over.

d. Cans of one gallon or more, stacked on pallets, will be stacked no more than two

deep in order to ensure a stable load and avoid tipping over. All other containers

will be transported in a way which ensures stable and safe transportation.

e. All containers shall be transported in an upright position.


7-7

f. Containers on pallets shall be banded, strapped, or positioned on the vehicle to

prevent tipping over. Caution must be exercised while banding, to avoid denting or

otherwise damaging containers.

g. Incompatible wastes shall not be transported on the same vehicle.

h. Unknown wastes are prohibited from transport except for a sample that is shipped

for testing and analyzing to determine its substance.

Hazardous wastes shall not be transported on any public road except by a State of

Alabama Licensed Hazardous Waste Transporter using a Hazardous Waste Manifest.

Personnel within DPW-ENRD are allowed to sign Hazardous Waste Manifests. They are

the only ones who have been granted signatory authority by the Garrison Commander.

All other off-post activities, which do not have prior authorization, must make

arrangements with an organization which is authorized to transport waste and sign the

manifest, or make other arrangements to provide for these requirements with appropriate

coordination and notification with DPW-ENRD.

Before any hazardous waste can be transported off-post, including waste generated by

contractors, it must be manifested in accordance with the requirements of Section 8.10,

with the contractor and Fort Rucker listed as the generator. Generators that manifest

waste on an irregular or infrequent basis should consult with DPW-ENRD about

appropriate profiling and manifesting procedures.

7.9 MANIFESTS

All generators who transport or contract for the transportation of hazardous waste for off-

site treatment, storage, or disposal must prepare a manifest. The manifest is a standard

EPA or state form, which lists the following:

• Generator's EPA ID number

• Generator's name and mailing address

• Generator's telephone number

• All transporter's names and EPA ID numbers

• Company name, site address, and EPA ID number for the facility designated to

receive the waste


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• Number and type of containers holding the waste

• Total quantity of waste

• Weight or volume of the waste

• DOT description (including proper shipping name, hazard class, ID number, and

packing group)

• Special handling instructions and other information

• Emergency Response Guidebook reference number

• Generator's written certification that the statements made is true

The hazardous waste service contractor through the DLADS has the responsibility for

preparing the manifests for waste being transported from the Fort Rucker 90-HWAS. The

organization-level generators must supply supporting information and data for the

manifest preparation in the form of container labeling information and turn-in documents.

Once the DLADS contractor has completed the EPA or state manifest form, the

handwritten signature must be obtained from the initial transporter, DLADS personnel,

and DPW-ENRD personnel, along with the date of acceptance of the manifest. The

contractor must reproduce enough copies of the manifest to provide the generator (Fort

Rucker), HMCC, each transporter, the DLADS, Cairns Army Airfield, and Shell Army

Heliport. When shipment is made, the generator retains the generator copy of the

manifest and gives the initial transporter the remaining copies. Manifest copies will be

kept for a minimum of three years.

DPW-ENRD maintains information on EPA-approved RCRA TSD facilities and

transporters. All hazardous waste produced on Fort Rucker must be disposed through

DPW-ENRD. Only personnel in DPW-ENRD have been delegated authority by the

Garrison Commander to sign hazardous waste manifests.

7.10 EXCEPTION REPORTING

If the installation does not receive a copy of the hazardous waste manifest with the

signature of the owner, operator, or authorized representative of the designated TSD

Facility within 35 days of the date the waste was shipped from Fort Rucker, the status of

the waste must be determined. The transporter and the TSD facility must be contacted to


7-9

confirm that the waste shipment was in fact delivered and accepted, and to obtain a copy

of the manifest. If the waste was not delivered or accepted, the location of the waste must

be determined.

If the installation does not receive a copy of the closed manifest within 45 days of the date

the waste was accepted by the initial transporter, an exception report must be submitted

to ADEM. The exception report must include a legible copy of the manifest for which the

confirmation of delivery is missing and a cover letter describing efforts taken to locate the

hazardous waste and the results of those efforts.

DLADS is responsible for exception reporting for wastes shipped through their contractor.

7.11 RECORDKEEPING

Fort Rucker DPW-ENRD is responsible for preparing, submitting (where required) and

maintaining the following records:

a. The annual ADEM Form 8700-12 and the EPA Biennial Report for the entire

installation in accordance with ADEM Administrative Code 335-14-3-.04(2) and 40

CFR 262.41.

b. Records consisting of copies of manifests, exception reports, LDR notifications,

and incident reports. Maintain training records for DPW-ENRD personnel as well

as all 90-day accumulation site managers.



EMS-P002, Document Control Procedure:

a. Fort Rucker HWMP (this document)

b. 90-HWAS and HWSAP inspection records

c. Hazardous waste training records (maintain for a minimum of three years)

d. Fort Rucker ISCP and SPCC Plan

e. Site Specific Spill Plan

f. DD Form 1348-1A turn-in documents

Each 90-HWAS Manager is responsible for maintaining the following records:

a. Weekly inspection records for the 90-HWAS.


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b. Training records on personnel operating the 90-HWAS.

7.12 HAZARDOUS WASTE REPORTING

A biennial hazardous waste report will be submitted to the ADEM by DPW-ENRD based

on hazardous waste disposal records for each reporting year by 1 March. These reports

will be based on calendar year data. These reports will be forwarded by the ADEM to the

US EPA Region IV in accordance with federal hazardous waste regulations.

Fort Rucker is also required to annually complete and submit ADEM Form 8700-12,

Notification of Regulated Waste Activity by 15 October.

SECTION EIGHT Hazardous Waste Analysis Plan

8-1

Section 8 Hazardous Waste Analysis Plan

8.1 GENERAL

Wastes must be characterized prior to disposal. Chemical and physical characteristics of

a waste must be determined in order to develop a waste disposal profile and decide

disposal options. Information will be obtained by user or process knowledge, SDS or other

manufacturer information, or through laboratory analytical methods or other test methods.

If a laboratory analysis is required, the Hazardous Waste Program Manager will

coordinate sample collection and shipment to an appropriate analytical laboratory. After

receiving/reviewing the analytical results, the Hazardous Waste Program Manager will

advise the organization of disposal procedures and will complete a hazardous waste

profile sheet. The Hazardous Waste Program Manager will determine the extent of

testing. Waste characterizations will be forwarded to DLADS for recordkeeping and

forwarding to waste disposal facilities.

When analysis of a waste stream is required, additional time must be allowed for

processing the waste prior to disposal. At least 30 days will be allowed for the analysis

and profiling to occur prior to required removal from a 90-HWAS. Results for routine

laboratory analysis for hazardous waste determination purposes will usually be returned

to the installation within two weeks of submitting the waste sample. After receiving results,

the Hazardous Waste Program Manager must determine the waste codes associated

with the waste and complete waste profile documentation.

8.2 ANALYSIS COST

Waste analysis samples submitted through DPW-ENRD are part of the management

contract for the hazardous waste facility. An account is established with a certified lab for

any wastes that need to be analyzed. Organizations are typically not charged for the cost

of the analysis; however, a situation may arise (i.e., gross negligence) where the

organization may be required to pay for the lab analysis. The Chief, DPW-ENRD is

responsible for determining organization charges, as appropriate.

8.3 CHAIN-OF-CUSTODY FORMS

Chain-of-Custody forms are used for all samples collected. The environmental laboratory

receives all samples using these forms and assigns a unique sample number (from a


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logbook) to each sample. When laboratory results are available, the Hazardous Waste

Program Manager is contacted by email with final lab results.

8.4 RESULTS

When laboratory results indicate hazardous waste characteristics are present, waste will

be processed by DPW-ENRD and transferred to DLADS for storage and disposal per

Section 8, Hazardous Waste Disposal Procedures.

The analytical lab must certify its use of the required EPA test methods and must be able

to provide documentation of quality control and quality assurance procedures. Acceptable

documentation may include compliance with the quality control section of each EPA SW-

846 procedure.

8.5 CHARACTERIZATION FREQUENCY

In general, testing will not be performed on unused hazardous materials that have been

turned in unopened and in their original packaging. Waste characterization of these items

is performed using the item’s physical and chemical characteristics contained in the SDS

as well as standard references to supplement label information.

Waste streams that are generated on a recurring basis are characterized annually or

when changes occur in the process. These annual characterizations and their results will

be reviewed by the Hazardous Waste Program Manager. Hazardous waste profile sheets

for these wastes will be maintained at DPW-ENRD and DLADS and updated as required.

Any non-recurring waste streams will be analyzed if required and profiled as they are

generated prior to acceptance by DLADS. Hazardous waste profile sheets will be updated

as required.

8.6 UNKNOWN WASTES

Unknown wastes are discovered on the installation from time to time. When this occurs,

the contents of these containers or “mystery drums” will be analyzed to determine if they

are a hazardous waste. Based on analytical and physical characteristic results, DPW-

ENRD will make the determination for safely moving these containers to a 90-HWAS if it

is determined to be a hazardous waste. The Fort Rucker Fire Department Hazardous


8-3

Material Response Team will respond to a “mystery drum or container” in emergencies

or when potential risk is suspected.

8.7 LAND DISPOSAL RESTRICTIONS

In accordance with the LDR regulations in ADEM Administrative Code 335-14-9 / 40 CFR

268, wastes shipped offsite may need to be analyzed to determine whether the waste

meets the applicable LDR treatment standards. If it is known that the wastes do not meet

applicable LDR treatment standards based on process knowledge, no testing will be

performed. Each waste for which a treatment standard has been set will be evaluated for

the applicable parameters in ADEM Administrative Code 335-14-9-.04 / 40 CFR 268.41-

43. All analytical results completed in support of LDR requirements will be retained at

DLADS.

Wastes resulting from facility operations that exceed applicable LDR treatment standards

will be sent offsite to a RCRA-permitted or interim status treatment facility. Applicable

LDR notifications will be supplied with the shipment of waste with the information required

under ADEM Administrative Code 335-14-9-.01(7) / 40 CFR 268.7(a)(1). In addition to

the LDR notification, any additional data for the waste stream (e.g., waste profile sheet,

analytical data) will be available, upon request.

For purposes of the LDR recordkeeping requirement, DLADS is the generator of the

waste that is to be shipped offsite. DLADS personnel will verify the restricted/prohibited

status of each waste stream prior to shipment, since this status is subject to change. The

notification and/or certification forms to be used may be provided by the treatment facility

that receives the waste. Copies of all notices, certification, demonstration, waste analysis

data, and other documentation produced for LDR recordkeeping purposes will be retained

on-site for at least three years from the date the waste was last sent offsite for treatment,

storage, or disposal. The record retention period may be extended during unresolved

enforcement action or at the request of the EPA Regional Administrator.


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SECTION NINE Hazardous Waste Minimization

9-1

Section 9 Hazardous Waste Minimization

Hazardous waste minimization is the reduction, to the extent feasible, of hazardous waste

that is generated prior to treatment, storage, or disposal of the waste. It includes any

source reduction or recycling activity which results in reduction in volume and/or toxicity

of waste consistent with the general goal of minimizing present and future threats to

human health and the environment. Examples include:

• Chemical substitution - replacement of hazardous chemicals with nonhazardous

or less hazardous chemicals.

• Process or methodology change - development of alternative processes or

methods that use smaller quantities or eliminate the use of hazardous chemicals,

which results in the generation of less waste.

• Segregation of wastes - ensuring that non-hazardous wastes are not contaminated

with hazardous wastes, which increases the total volume of hazardous waste, and

ensuring that otherwise recyclable hazardous wastes remain recyclable because

they are not contaminated by non-hazardous or other hazardous wastes.

• On-site recycle - such as distilling solvents on-site for on-site reutilization.

• Off-site recycle - when possible and economically practical, manifesting hazardous

wastes to off-site recycling companies rather than to disposal or treatment for

disposal.

Commanders and directors will take measures to reduce and minimize the volume and/or

toxicity of hazardous waste generated within their activities whenever practical and in

conformance with the Fort Rucker Pollution Prevention Plan. These measures shall

include implementation of the measures listed above as appropriate and applicable,

including the designation of a pollution prevention coordinator.

9.1 POLLUTION PREVENTION PLAN

Fort Rucker has a Pollution Prevention Plan, which satisfies EPA and ADEM hazardous

waste minimization requirements according to RCRA. The current objective for hazardous

waste reduction uses the CY 2012 hazardous waste quantities as a baseline and

investigates hazardous wastes that are generated on a recurring basis to identify areas

where the amounts of these materials can be reduced and maintained. Personnel have

already investigated or have initiated several pollution prevention projects/efforts. These


9-2

pollution prevention efforts include: replacing the contractor-provided solvent recycle

service with parts washer machines which recycle solvent through a filter-eliminating

liquid replacement; continued use absorbent; digital photographic equipment eliminating

waste silver recovery; and recycling of antifreeze, batteries, and fluorescent bulbs. These

efforts are considered sufficient to allow certification to be made on the manifests that a

waste minimization program is in place.

DPW-ENRD prepares and administers the Pollution Prevention Plan with input from

waste generators. The AR 200-1 requirement that the HWMP describe waste

minimization projects, funds, and savings is satisfied by the Pollution Prevention Plan.

For this reason, the Pollution Prevention Plan is incorporated into this section of the

HWMP by reference, and a copy is available on the Sustainable Fort Rucker website.

9.2 HAZARDOUS MATERIALS

Unused hazardous materials are managed through the Hazardous Material Management

Program (HMMP). A large aim of the HMMP is to reduce the generation of hazardous

waste that results from the use of hazardous materials throughout Fort Rucker. Fort

Rucker Regulation 710-3 establishes the HMMP with a core objective of improving

“logistics and operational mission performance by controlling and reducing the

acquisition, use, handling, and disposal of HM and the generation of HW, consistent with

Army supply chain integration and sustainability objectives.” Additional information about

the HMMP is contained in Section 11 of the Pollution Prevention Plan and on the

Sustainable Fort Rucker website.

As part of the overall HMMP, DPW-ENRD developed USAACE Form 2730, Hazardous

Material Authorization Request, for organizations to use to request addition of a

hazardous material to their authorized use list. This form allows approval from installation

organizations that are involved in hazardous material management and minimization of

waste generation. A copy of this form is located in Appendix N.

9.3 EMS OBJECTIVES AND TARGETS

Each year, the EMS Management Representative and EMS Implementation Team review

and update the installation’s objectives and targets, considering the installation’s


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significant environmental aspects; applicable legal and other requirements; technological

options; relevant financial, operational, and business requirements; and, pollution

prevention opportunity assessments. Because hazardous waste generation is one of the

significant aspects within the Fort Rucker EMS, it is included in the development process.

After identification of an objective relating to hazardous waste, the Hazardous Waste

Program Manager develops a plan that includes the means and timeframe for

achievement utilizing USAACE Form 2724, Objectives and Targets Action Plan. The

Hazardous Waste Program Manager is responsible for tracking progress in achieving the

objective and for reporting to the EMS Implementation Team and the EMS Management

Representative (EMSMR).

The current objective for this program is to reduce hazardous waste disposal by 15% by

CY2020 from a baseline year of CY2012. The Hazardous Waste Program Manager

maintains and updates the USAACE Form 2724, Objectives and Targets Action Plan, to

ensure continued progress in meeting this goal.


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SECTION TEN Installation Waste Stream Summary

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Section 10 Installation Waste Stream Summary

10.1 GENERAL

Hazardous waste, non-hazardous waste, and Universal Waste are handled regularly.

This section is a general summary of the different types of wastes that are generated at

Fort Rucker. Section 12 contains more details regarding the handling and specific

management practices for the most commonly generated waste streams. The Hazardous

Waste Program Manager reviews the profiles and any laboratory analysis prior to signing

any waste manifests to ensure proper waste characterization, management, and

disposal. Copies of all profiles are maintained at DPW-ENRD.

The following major activities generate hazardous waste and non-hazardous waste with

special handling requirements:

• Aviation Maintenance

• Building Maintenance

• Construction Activities

• Fuel/Oil Transfer and Storage

• Ground Vehicle and Equipment Maintenance

• Laboratory Operations

• Medical and Related Research Activities

• Military Training Activities

• Painting Activities

• Photo and X-Ray Activities

• Supply Excess

10.2 HAZARDOUS WASTE

Common hazardous waste streams generated at Fort Rucker are:

• Absorbent materials – contaminated with cadmium, chromium, and/or lead

• Absorbent materials/filters – contaminated with paint

• Paint and thinner

• Abrasive blast media

• Clarus parts washer solvent and filters


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• Fixer/developer

• Caustic cleaning compounds

• Plating shop solids

10.3 NON-HAZARDOUS WASTES

These wastes are not regulated as RCRA hazardous waste, but still require special

handling and disposal actions to ensure that other regulations are not violated. Non-

hazardous wastes may be accumulated and stored in a HWSAP. Although these wastes

are usually not subject to RCRA hazardous waste regulations, they can become a

hazardous waste if they are mixed with or contaminated by a hazardous waste. Common

non-hazardous wastes on Fort Rucker are:

• Asbestos

• Grease

• Latex paint

• Nonflammable adhesives

• Oil, fuel, and grease contaminated rags and debris

• Oil and fuel filters

• Petroleum, Oil, and Lubricant (POL)-contaminated soils and used dry sweep

(except for gasoline)

• Used antifreeze

• Used oil

• Zyglo rinsate

10.4 UNIVERSAL WASTE

Universal wastes regularly managed at Fort Rucker include batteries, fluorescent lamps

(unbroken), mercury containing equipment (thermostats, thermometers), and certain

pesticides. Because of their widespread use in industry and the government, universal

waste can be stored for a longer period of time than hazardous waste and does not

require shipment under a hazardous waste manifest.


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10.5 PROHIBITED ITEMS

Prohibited items are items that must be kept from regular garbage and dumpsters. EOs

and EPOCs should frequently inspect dumpsters in organizational areas and facilitate the

proper disposal of any inappropriate items found in dumpsters. The following items are

not permitted in regular garbage and dumpsters:

• Hazardous waste

• Antifreeze

• POL products

• Used oil and fuel filters

• Contaminated soil

• Paint

• Fluorescent bulbs

• Used dry sweep and absorbents

• Bulk MRE heaters

• Pesticides

• Non-alkaline batteries

• Aerosol cans

• Tires

• Blast media

• Nuclear, biological, and chemical (NBC) items

• Solvent and filters

• Hazardous materials

• Ammunition-related items (anything issued by the ammunition supply point [ASP])

• Used/dirty rags

10.6 POLYCHLORINATED BIPHENYLS

Polychlorinated biphenyls (PCBs) are synthetic compounds used widely as a dielectric

fluid in transformers and capacitors, in light ballasts, and for other insulating uses prior to

1978. PCBs are regulated by the Toxic Substances Control Act (TSCA) and under 40

CFR 761. TSCA requires that all items manufactured after 1978 be labeled as to whether


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the item is PCB or non-PCB containing. When no identifying label is present, assume that

it contains PCBs and contact the PCB program managed within DPW-ENRD. Fort Rucker

has no known remaining PCB items in service or storage on the installation. However,

some items, such as ballasts, may be discovered during maintenance of older facilities.

Organizations should contact DPW-ENRD for further guidance if any potential PCB

containing items are identified. Copies of the PCB logs are maintained in DPW-ENRD.

10.7 REGULATED MEDICAL WASTE (RMW)

Regulated medical waste (RMW) is waste that is potentially capable of causing disease

in humans and may pose a health risk to individuals, the community or both, if not handled

or treated properly. All medical waste is managed through Lyster Army Health Clinic.

RMW includes the following:

• All sharps, used and unused

• Free flowing blood or blood products including blood specimens, vials and blood

in bags

• Any item saturated or dripping with blood or body fluids

• Pathological specimens

• Microbiological waste such as cultures, stocks, and vaccines

SECTION ELEVEN Waste Stream Management

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Section 11 Waste Stream Management

The following sections describe specific management procedures for hazardous wastes,

universal wastes, and non-hazardous wastes that are commonly encountered during daily

operations at Fort Rucker.

11.1 ABSORBENT MATERIALS

11.1.1 Continued Use Absorbents The absorbent continued use program is designed to be a closed-loop system where

used absorbent materials are returned to the vendor for cleaning and returned to the

generating facility for reuse. Before the absorbent continued use program was

implemented, maintenance personnel used disposable absorbent items in daily

maintenance activities. These materials were characterized as hazardous waste due to

the presence of cadmium, a toxic metal commonly used in aircraft and aircraft

components. DPW-ENRD petitioned ADEM for approval of the program, which was

granted on 27 April 2005. Organizations should consult EMS-WI-SW009, Absorbent

Continued Use Program to ensure proper implementation of the program. A copy of this

work instruction is located in Appendix O.

The following items are available for use through the program:

• Pads

• Socks

• Wipes

• Gloves

• Mopheads

• Pillows

After the items have been used, personnel place them into designated containers located

in the operational area. These containers are then collected by the continued use

absorbents vendor for laundering. After laundering, the vendor returns the material to Fort

Rucker for reuse.

Organizations should use USAACE Form 2732, Continued Use Absorbents Tracking

Document, to record turn-in and receipt of the absorbents and provide DPW-ENRD with

drum identification numbers, deliver/pickup date, total weight and number of drums


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received and returned using USAACE Form 2732, Continued Use Absorbents Tracking

Document, no later than 7 days after delivery or pickup.

A copy of this form is located in Appendix P.

11.1.2 Disposable Absorbents Absorbents, including paper or cloth wipes, rags, filters, spill pads, and booms that are

not part of the continued use program and that are contaminated with hazardous

materials, including paints and other materials, must be collected and managed as a

hazardous waste in a HWSAP in accordance with Section 5 unless sampling has been

completed to document otherwise.

Oil and fuel (except motor gasoline [MOGAS]) contaminated absorbents are not

hazardous waste if no other product has contaminated them. However, these used

absorbents should be collected separately in a container labeled “ABSORBENTS

CONTAMINATED WITH OIL” and turned in to the 90-HWAS for proper disposal as a non-

regulated waste. Oil and fuel (except MOGAS) contaminated rags may be laundered if

not saturated or may be disposed through the 90-HWAS. Materials contaminated with

MOGAS should be collected and managed in a HWSAP in accordance with the

procedures in Section 5.

11.1.3 Sweeping Compound Sweeping compound, including oil-dry, sand, or vermiculite, saturated or contaminated

with a hazardous substance, must be managed as a hazardous waste in a HWSAP in

accordance with Section 5. Sweeping compound contaminated with MOGAS should be

managed as a hazardous waste in a HWSAP in accordance with the procedures in

Section 5. Sweeping compound, saturated or contaminated with oil or fuel (except

MOGAS), should be managed as a non-regulated waste and turned in to the 90-HWAS

for disposal.

POL-contaminated dry sweep and soil must never be thrown in a dumpster, trash can, or

landfill. Dry sweep should be collected in a container and labeled as “USED DRY

SWEEP.” The container must have a lid and be kept closed at all times. Contaminated

dry sweep and soil are turned in to the main 90-HWAS. All soil and dry sweep must be


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free of debris (i.e., plastic bags, buckets, cans). This material is then disposed through a

DLADS contract.

11.2 ADHESIVES

Adhesives are used during maintenance activities for aircraft and ground vehicles.

Adhesives that are two-part mixtures that are chemically cured or air cured prior to use

are hazardous wastes due to their flashpoint. Small amounts of unused adhesive, stir

sticks, and mixing cups with adhesive residue may be thrown into the trash after drying.

11.3 AEROSOL CONTAINERS

All aerosol containers, including empty and malfunctioning containers, must be turned in

to the HMCC for proper management and/or disposal. Generators should collect aerosol

cans that are no longer being used in the operational area in a container marked “HazMat

for Return to HMCC.” The HMCC will make the determination of aerosol serviceability.

Containers with product may be put into the Free Issue Program. Aerosols that are not

functioning or empty will be punctured and processed as scrap metal by the HMCC.

Appendix F contains ADEM guidance on management of used aerosol cans.

11.4 ANTIFREEZE

Antifreeze (ethylene glycol, or the less toxic propylene glycol) should be collected in an

approved plastic container that is labeled “USED ANTIFREEZE” and that is kept closed

when not adding or removing used material. The container should have secondary

containment to prevent potential spills from contaminating stormwater. Organizations

should ensure that used oil is not mixed with the antifreeze in order to ensure the

antifreeze can be recycled.

The used antifreeze container should be turned in to the centralized 90-HWAS for

recycling. Although used oil and antifreeze are not classified as hazardous wastes, they

should be handled with the same care as hazardous wastes, since spills of these

substances require response under the Fort Rucker ISCP.

Antifreeze should never be poured into a storm drain or in an oil-water separator.


11-4

11.5 ASBESTOS

Asbestos containing material may be generated as part of renovation and demolition

projects being conducted on the installation. Samples of any suspected asbestos

containing material (ACM) are sent to a lab for verification. If ACM is generated for

disposal, the material should be collected in accordance with ADEM regulations. ACM

may be disposed of in any permitted landfill in Alabama with written approval from ADEM,

following the special waste provisions found in ADEM regulations at ADEM Administrative

Code 335-13-4- .26(2).

11.6 ASPHALT AND RELATED WASTES

Asphalt is used as a paving material on most installation roads. In general, contractors

that perform road maintenance activities should dispose of all waste that is generated as

a part of their activities. The contractor should coordinate with DPW-ENRD regarding

these wastes to determine proper management procedures. Asphalt contractors should

always use all material for its intended purpose to the greatest extent possible.

The DPW Roads and Grounds Section also uses an asphalt emulsion when cleaning out

asphalt residue in vehicles that are used for road repair activities. This residue from

cleaning operations should be containerized in approved containers and managed in a

HWSAP in accordance with the procedures contained in Section 5.

11.7 BATTERIES

11.7.1 General Requirements Fort Rucker generates batteries from military-specific applications, such as radios,

vehicles (both military and civilian), and aviation equipment, and from general operations

such as computers and cell phones. New batteries must be stored in their original

packaging in a cool, dry location. Batteries that have been removed from their original

packaging must be clearly segregated from new batteries, including batteries considered

used and in use.

While accumulating used batteries for turn-in, they must be placed in a properly labeled,

DOT approved container with a closing lid; or, for larger lead-acid batteries, stored in

covered areas on pallets or in a covered spill containment pallet. Batteries should not be


11-5

stored directly on the ground or the floor. All batteries must be stored with consideration

for potential compatibility issues. Water reactive batteries should be stored a minimum of

six inches above the floor or ground.

Batteries of any type can be dangerous, especially if swollen, broken, leaking, or

improperly vented. Leaking or damaged batteries (dry cell or sealed) must be segregated

from intact used batteries inside the container by placing the leaking or damaged battery

in a sealed plastic bag or wrapped with plastic and sealed using tape. Lead-acid batteries

that are leaking or are damaged (e.g., cracked case) will be accumulated in a HWSAP

for disposal as hazardous waste.

Organizations and activities must not accumulate more batteries than are manageable.

The organization and activities should consider such factors as storage space, usage

rates, packaging costs, man-hours, and safety when accumulating batteries.

Any quantity of batteries may be stored at one time, but Fort Rucker organizations are

encouraged to transfer the batteries to the HMCC prior to accumulation of a large quantity.

Organizations must transfer universal waste batteries to the HMCC or 90-HWAS within

six months of the accumulation start date to ensure sufficient time remains to allow for

processing for disposal.

Organizations should not discharge lithium sulfur dioxide (LiSO2) batteries on Fort

Rucker.

Used or unusable batteries such as Lithium, Nickel-Cadmium (NiCd), Mercuric-Oxide

(button and other), Nickel Metal Hydride (NiMH), Silver Oxide, Silver-Zinc, Zinc-Carbon,

and Zinc Air batteries will be managed as Universal Waste. Containers and/or areas used

for storing universal waste batteries must be labeled with the words “UNIVERSAL

WASTE BATTERIES” and the date that the first battery was placed in the container

(accumulation start date). Universal waste batteries should have their connectors taped,

and the batteries should be placed in an approved container. Like batteries are

containerized together. These containers must be stored as universal waste and turned

in to the HMCC, Bldg 1315 for recycling.


11-6

Used single-use dry cell Alkaline and Carbon-Zinc batteries (e.g., 9-volt, D, C, AA, AAA,

alkaline button) are managed as Non-Hazardous Waste.

EMS-WI-SW002, Used Battery Management, in Appendix Q, provides guidance for

proper labels, signs, storage, and turn-in procedures for used batteries.

11.7.2 Small Rechargeable Batteries Fort Rucker has two programs for recycling small rechargeable batteries, such as NiCd,

lithium ion, and NiMH batteries.

The main program that Fort Rucker is working with is Call2Recycle. This nonprofit

organization offers consumers and retailers in the United States and Canada simple ways

to recycle old phones and rechargeable batteries. Call2Recycle drop-boxes are located

in the HMCC.

Fort Rucker has also partnered with Cell Phones for Soldiers, which works to turn old cell

phones into more than 12 million minutes of prepaid calling cards for U.S. troops stationed

overseas. Drop off locations on Fort Rucker are at the Recycling Center (Building 9322),

DPW-ENRD office, and the HMCC.

11.7.3 Lead Acid Batteries Fort Rucker participates in a battery program that is a one-for-one exchange of new and

unserviceable batteries for lead-acid batteries. A contractor supplies new batteries to

organizations and picks up any used batteries that have been collected. The

unserviceable batteries are handled and transported by the contractor to a battery

recycler for recycling. The contractor takes the entire battery (including the electrolyte

solution). If the contractor does not have a particular facility on the pickup route, the

organization may turn in their used lead-acid batteries to the HMCC.

Any batteries with a cracked case cannot be returned to the vendor as part of this

program. These batteries should be accumulated in a HWSAP and turned in to the 90-

HWAS for disposal as hazardous waste.

Draining batteries before collection is not necessary. Both new and used batteries should

be stored in covered areas on pallets or in a covered spill containment pallet. These

batteries do not need to be labeled as universal waste.


11-7

Although the batteries are not managed as universal waste, the organization should not

accumulate the batteries for an extended period of time. Organizations should implement

a method to demonstrate how long the batteries have been stored between shipments.

11.8 BATTERY FLUID

Historically, battery shops have been used for maintaining wet cell batteries. Battery

shops are no longer major sources of hazardous waste generation. The operations in

these areas have been scaled down significantly due to an Army-wide implementation of

a closed-loop battery program. Wastes that are generated from these processes, such as

electrolyte solutions, are usually corrosive and must be disposed as hazardous waste.

Personnel should collect these wastes in an approved non-metal container or a metal

container with an appropriate liner in a HWSAP in accordance with the procedures

described in Section 5. Any personnel generating these types of wastes should

coordinate with DPW-ENRD to ensure that these wastes are properly containerized due

to the corrosive nature of the waste. Any cracked batteries must also be collected in a

HWSAP in accordance with the procedures in Section 5.

11.9 BLAST MEDIA

Blast media is used prior to painting as well as to ensure complete cleaning of parts during

specialized maintenance activities. Blast media is used in a blasting booth that reuses the

media until it is no longer useful for blasting purposes due to having particles that are too

fine to be effective. Personnel at the blast facility should check the quality of the blast

media that is removed by the filtration system to determine whether it can be reused. If

the blast media can be used again, it should be added to the blast media that is supplied

to the booth. Blast media that is no longer effective must be stored and managed as a

hazardous waste in a HWSAP in accordance with the procedures described in Section 5.

Blast media is usually contaminated with metal and paint particles, which cause it to be

hazardous waste. Filters used during blasting operations may also be hazardous due to

filtration of the same metal and paint particles contained in the blast media from the air.

Prior to disposal of these items, organizations should contact DPW-ENRD to verify the

waste classification.


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11.10 BOILER TREATMENT

Use of boiler treatment chemicals is periodically required to ensure proper operation of

equipment and to remove and prevent mineral buildup. Various types of corrosive

chemicals are used to remove buildup of scale during routine maintenance of these

systems. The heat plant operators should coordinate with DPW-ENRD when generation

of a waste results from these operations. In general, the materials are used completely

during the cleaning process. However, when a waste is generated, the waste should be

collected in an approved container designed for corrosive materials and accumulated in

a HWSAP in accordance with the procedures described in Section 5.

11.11 CORROSION PREVENTION AND REMOVAL

Corrosion is a large maintenance concern for Army vehicles and equipment. In order to

minimize the costs associated with removing corrosion and replacing corroded

equipment, the Army has implemented aggressive corrosion control programs. Part of

these programs involves the application of various compounds designed to prevent and

remove corrosion on all types of military equipment. Waste that is generated as a result

of these activities includes various corrosion preventative and preservative coatings used

to prevent rust on materials and equipment as well as corrosion removing compounds.

These wastes are often classified as hazardous waste and should be accumulated in an

approved container at a HWSAP in accordance with Section 5.

11.12 CYLINDERS

Types of cylinders disposed in the past include ammonia, oxygen, nitrogen, acetylene,

butane, propane, engine starting fluid (ether), and fire extinguishers. When disposing of

cylinders, the organization should coordinate with DPW-ENRD regarding the types,

quantities, and locations of the cylinders, preparing the necessary disposal

documentation, and coordinating with DLADS for their disposal. When possible, these

cylinders should be returned to the vendor for reuse or recycling rather than being

disposed through DLADS.


11-9

Quick Start ether cylinders should be returned to the vendor rather than disposed as

hazardous waste. Organizations are required to use this program for these cylinders

because of the high cost for disposal through DLADS.

When refrigerant cylinders (non-refillable) are empty, personnel should punch a hole in

each cylinder. The cylinders should be crushed and turned in to DLADS for scrap metal

recycling.

11.13 EMPTY CONTAINERS

In general, containers are considered empty when there is less than one inch of residue

on the bottom or less than three percent by weight remaining in the container. Empty

containers must be kept closed at all times.

Empty containers that are to be turned in to DLADS must be properly marked with the

word "EMPTY" and DOT shipping name and UN/NA ID number of previous contents.

Empty containers which previously held hazardous materials bearing a DOT hazardous

warning label, such as flammable liquid, corrosive, etc., must continue to bear this label

unless cleaned and purged of all vapors. Containers must be completely free of holes

and have all caps, lids, plugs, etc., affixed. Empty containers that are going to be reused

by the organization must be marked “EMPTY” and with the previous contents. Containers

must be in good condition for reuse. If the product came through the HMCC, approval

must be received from the HMCC before reuse of the empty container.

Empty containers which have contained hazardous materials or hazardous waste, other

than acutely hazardous waste listed in ADEM Rule 335-14-2-.04(2), (3), and (4)(e), and

which are over five gallons, will be drained to less than one inch of residue; marked

“EMPTY” and with the chemical name of the original contents; and may be turned in to

the HMCC. All containers must be closed and non-leaking. Some containers, such as

small alcohol or oil containers, may be drained and disposed in a dumpster in the

organizational area. The Hazardous Waste Program Manager will provide guidance for

specific containers upon request.


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11.14 FUEL

MOGAS is highly ignitable and must not be mixed with any other type of fuel.

Contaminated MOGAS should be stored as a hazardous waste in a HWSAP managed in

accordance with the procedures described in Section 5. MOGAS must always be stored

in a grounded, approved metal container.

F24, diesel and kerosene contaminated with water must be collected in a metal 55-gallon

drum or an aboveground storage tank. The drum or tank should be labeled with the

contents of the container and have appropriate secondary containment. MOGAS, oil,

antifreeze, and solvents should not be mixed with the fuel. Mixing these materials may

create a hazardous waste that cannot be recycled or reused. When the container is

approximately 75 percent full, the organization should contact DPW-ENRD to schedule

removal of the fuel.

11.15 FUEL FILTERS

Once used fuel filters are removed from a vehicle, the residual fuel should be drained into

an approved metal container designated for collection of contaminated fuel. The filters

are not required to be drained for any set length of time, but should be drained long

enough to remove free flowing liquid. Organization personnel must not leave the fuel

filters unattended while draining.

For used MOGAS filters, after draining, the filters must be stored as hazardous waste in

an approved metal container in a HWSAP and managed in accordance with the

procedures described in Section 5.

For all used F24 or diesel filters, crush filters in a suitable machine so that the scrap metal

can be recycled and the used fuel captured and transferred into the used fuel

accumulation container or tank.

The container used to collect the drained fuel is managed according to the procedures

described in Section 11.14. Additional details about management of these filters may be

found in EMS-WI-SW007, Management of Used Oil and Fuel Filters, a copy of which is

located in Appendix R.


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11.16 GREASE AND RELATED ITEMS

Grease, Automotive and Aviation (GAA) is used in many applications for vehicle and

aircraft maintenance throughout Fort Rucker. Every effort should be made to completely

use all product in containers before opening a new container or disposing open

containers. Any waste GAA or other grease is stored in an approved, labeled container

and turned in to the HMCC for disposal. This waste is generally not a HW, but it is

managed through DPW-ENRD due to restrictions on disposal of this material in landfills.

11.17 IMAGE INTENSIFIER TUBES

Image intensifier tubes that are part of the night vision devices must be demilitarized

before they can be disposed. Fort Rucker organizations may demilitarize the intensifier

tubes at the installation in accordance with published Army guidance. Both demilitarized

and cracked or damaged image intensifiers should be collected in a HWSAP and

disposed as hazardous waste in accordance with the procedures in Section 5.

11.18 INSECT REPELLANT

Permethrin insect repellant is used in military applications and comes in either an aerosol

can or an application kit consisting of a vial of permethrin with a plastic bag. Prior to

collecting for disposal, organizations should coordinate with other installation

organizations to ensure that they do not have a need for these items. The insect repellant

is used during most training exercises and during deployments. When these items must

be disposed, both the aerosol and vial forms of the insect repellant should be managed

as hazardous waste. They should be accumulated separately in approved containers in

a HWSAP in accordance with the procedures contained in Section 5.

11.19 MEDICAL ACTIVITIES

All regulated medical waste (RMW) must be managed through Lyster Army Health Clinic.

All RMW is incinerated by a contractor at an off-site facility. RMW generated on Fort

Rucker should be managed in accordance with local requirements. Organizations should

contact the Department of Preventive Medicine at 334-255-7012 for additional information

and guidance.


11-12

11.20 MERCURY-CONTAINING LAMPS

Fluorescent and high intensity discharge (HID) lamps (bulbs) contain low levels of

mercury, which fail the TCLP analysis for an item to be disposed of in the municipal

landfill. Used lamps are to be collected in a box, marked with the words “UNIVERSAL

WASTE” and “Used Lamps” and with the date the first lamp was placed in the box. The

box must be kept closed at all times except when adding or removing bulbs. All

fluorescent and HID lamps, including mercury vapor, metal halide, and high-pressure

sodium lamps, must be managed as universal waste, as described in EMS-WI-SW003,

Used Lamps Management. A copy of this work instruction is located in Appendix S.

Broken lamps must be collected, doubled-bagged in plastic bags, and containerized in

accordance with the procedures in EMS-WI-SW003, Used Lamps Management, a copy

of which is located in Appendix S. The collected waste should be managed as a

hazardous waste in a HWSAP or 90-HWAS in accordance with the procedures in Section

5 and 6. Vacuums/HEPA vacs will not be used to clean up broken lamp spill residue

because the mercury vapor may be released when heated during subsequent uses of the

equipment.

11.21 MERCURY-CONTAINING EQUIPMENT

Mercury-containing equipment means a device or part of a device (including thermostats,

but excluding batteries and lamps) that contains elemental mercury integral to its function.

Thermostats and thermometers that contain mercury are the most common types of this

equipment found on Fort Rucker.

Organizations manage these items as a universal waste when they are no longer usable.

The items are stored in a closed container that is labeled “UNIVERSAL WASTE -

MERCURY CONTAINING EQUIPMENT.” The date that the items were first placed in the

container is also indicated. Because the thermostats and thermometers can be easily

broken, care must be taken when packaging this waste. Organizations should obtain

vermiculite to package these items in a manner to prevent accidental breakage. When

the container is full, the organization should turn in the waste to the HMCC for disposal

through the DLADS contractor.


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11.22 MILITARY MUNITIONS

Military munitions must be handled and stored responsibly to minimize the potential for

harm to human health and the environment. All military munitions should be stored in

accordance with DOD 6055.9-STD, which establishes explosives safety standards.

Waste military munitions (WMM) must be managed in accordance with the Munitions Rule

(ADEM Administrative Code 335-14-7-.13 / 40 CFR 266 Subpart M), the Munitions Rule

Implementation Policy (MRIP), and any applicable federal, state, or local regulations. In

the event such regulations conflict with DOD 6055.9-STD, Fort Rucker will follow DOD

6055.9-STD for purposes of explosive safety until the conflict is resolved.

Military munitions and related items must be certified as inert prior to disposal. This

certification must be performed by qualified personnel as described in the MRIP. The

organization generating waste is responsible for ensuring that the items are certified inert

prior to being turned in. These items should not be accumulated in organization areas; all

military munitions should be turned in to the ASP for proper management.

11.23 NUCLEAR, BIOLOGICAL, CHEMICAL (NBC) ITEMS

Some NBC items require disposal as a hazardous waste when they can no longer be

used for their intended purpose. The waste determination should be made by DPW-

ENRD personnel prior to accumulation in the organization area. A HWSAP should not be

established in the NBC rooms in organization areas if these items are determined to be

a hazardous waste. Items that are generally classified as hazardous waste include

protective mask filters, M72A2 chemical agent ID kits, M256A1 chemical agent detector

kits, M229 chemical agent alarm refill kit, M258A1 decontamination kit, DS2 decon

solution, and STB.

11.24 PAINT RELATED ITEMS

11.24.1 Latex Paint Latex paint that has expired or is not needed is stored in an approved, labeled container

and turned in to the HMCC for reissue or disposal through DLADS. Latex paint is generally

not a hazardous waste. Paint cans from latex paint may be placed in a regular dumpster

after all of the paint has been used and the inside of the container is dry.


11-14

11.24.2 Hazardous Waste Paint and Thinner Unusable enamel, Chemical Agent Resistant Coating (CARC) paint and leftover paint

thinner must be managed as a hazardous waste in a HWSAP in accordance with the

procedures described in Section 5. CARC paints are particularly hazardous and may

degrade while in the can and become unusable. For example, CARC Component "B"

should be clear to pale yellow. If it thickens and appears crystalline in consistency,

organizational personnel should reseal it and return it to the HMCC.

11.24.3 Paint Containers In general, all containers of unusable or outdated paint must be turned in to the HMCC,

Bldg 1315. Partially used cans of paint must be returned to the HMCC. Paint cans should

be managed in a manner to meet the RCRA definition of empty as specified in 335-14-2-

.01(7)(b)(1) / 40 CFR 261.7(b)(1). Any paint in cans should be removed using practices

commonly employed for emptying the containers, primarily pouring. Also, the cans should

have less than one inch or three percent by weight of the container capacity of paint

remaining. Paint cans from other types of paint must be turned in to the HMCC for proper

disposal.

11.24.4 Paint Solids Paint solids are generated at most paint booths. These solids include filters generated at

paint booths, plastic sheeting that catches overspray in the paint booths, dried paint

scraped from surfaces, and any other items that contain dried paint. Paint solids that may

contain lead based paint (LBP) may also be generated during renovation and demolition

projects. Any solids determined to be hazardous waste should be managed in a HWSAP

in accordance with the guidelines in Section 5. DPW-ENRD will provide management

guidance based on the type of paint solids that are generated.

11.25 PARTS WASHER SOLVENT AND FILTERS

Parts washers are used in maintenance operations for ground vehicles, aircraft, and

ground and aviation equipment on the installation. As a result of their widespread use,

solvent wastes have been drastically reduced due to implementation of multiple waste

minimization initiatives. Parts washers on Fort Rucker are Clarus machines that are

owned by the installation and serviced by personnel with the HMCC. Maintenance is


11-15

performed by the facility maintenance contractor. Personnel must prevent contamination

of parts washer solvent by prohibited materials, such as paints. Contamination of the

solvent in installation owned parts washers will prevent this solvent from being filtered

and reused. The Clarus machines have built in filtration systems that extend the life of the

solvent. DPW-ENRD also has an external filtration machine that is being used to further

filter solvent used for ground equipment. This initiative may be expanded to include

aviation equipment after additional analysis is completed on the filtered solvent.

Solvent and filters generated by some organizations has been determined to be

nonhazardous through laboratory analysis. DPW-ENRD maintains records of the analysis

results and will ensure the waste from these organizations is appropriately disposed as

nonhazardous waste. The HMCC is responsible for changing all solvent and is

responsible for ensuring its proper management. Organizations with parts washers do not

generally have a HWSAP established for used parts washer solvent.

11.26 PESTICIDES, HERBICIDES, AND RODENTICIDES

Pesticide use is regulated under the Federal Insecticide, Fungicide, and Rodenticide Act

(FIFRA). Because the use and application of pesticides is strongly regulated, Fort Rucker

has a contract that covers most pesticide applications. Organizations are not permitted to

have large quantities of pesticides, herbicides, insecticides, and rodenticides stored in

their areas. Any waste generated by contractors should be properly containerized and

manifested when it leaves the installation. A DPW-ENRD representative must sign all

manifests of contractor-generated waste prior to the waste being shipped off-site.

Some pesticides may be hazardous due to their toxicity. DPW-ENRD provides additional

guidance on proper management of these items as they are generated on a case-by-case

basis. Aerosol pesticides, herbicides, and rodenticides should be managed as described

in the aerosol section above.

Pesticides that meet the definition of hazardous waste may be managed as universal

waste if they are recalled pesticides or stocks of unused pesticides collected as part of a

waste pesticide collection program, as described in ADEM Administrative Code 335-14-

11-.01(3) / 40 CFR 273.3. DPW-ENRD will make a determination of the management

method on a case-by-case basis. Any waste that is generated by organizations should be


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collected in an approved container in a HWSAP managed in accordance with Section 5

unless otherwise directed by DPW-ENRD.

11.27 PHOTO PROCESSING CHEMICALS

Some photographic waste solutions are hazardous due to corrosivity. Other photographic

waste solutions are not classified as hazardous waste due to the precious metal

exemption. Photographic waste solutions classified as hazardous waste are stored in

approved plastic containers in a HWSAP managed in accordance with the procedures

described in Section 5. Recyclable materials from which precious metals (i.e., silver) are

recovered are exempt from full hazardous waste regulation; however these materials are

subject to administrative requirements such as using manifests and complying with LDR

notification requirements.

11.28 PLATING SHOP WASTES

Plating solutions and solids contaminated with the plating solutions are generated at the

Cadmium Plating Shop at AMSS (Building 1001). Both the liquids and solids from each

shop should be managed in a HWSAP. The liquid waste and the solids waste should be

accumulated in separate 55-gallon drums in the plating shop. If necessary, the liquid

waste drum may be fitted with a funnel for adding waste to the drum. However, the funnel

must be attached securely to the drum bung and equipped with a closing mechanism that

will prevent spilling in the event that the drum is overturned.

11.29 POLYCHLORINATED BIPHENYLS

Fort Rucker is not aware of any PCB items still in use on the installation. Although all

known PCB items have been disposed, the potential exists for additional items to be

discovered due to the large area covered by the installation. If any items containing PCBs

are discovered, the items will be managed in accordance with TSCA and the guidelines

of this section.

PCB-contaminated (more than 50 ppm) oils, solid waste, soils, and rags contaminated

with fluids require disposal as TSCA regulated waste. All materials commonly

manufactured with PCBs in the past are still considered to contain PCBs unless testing

is feasible, or unless the equipment or item is marked by the manufacturer to indicate “no


11-17

PCBs” or “non-PCB.” The main source of PCBs is electrical transformers. When

transformers are taken out of service, or when other suspected PCB-containing items are

encountered, a screening test is performed to determine if the items are contaminated

with more than 50 ppm PCBs. Organizations should contact DPW-ENRD to arrange for

the testing.

PCB-contaminated wastes should be turned in to the HMCC for storage and disposal.

Items that are known to contain above 50 ppm PCB are manifested and removed from

the HMCC by a DLADS service contractor. PCBs are regulated under TSCA, and many

PCB management requirements differ from hazardous waste management requirements.

TSCA (40 CFR 700-789) should be consulted to ensure compliance with management

requirements.

A DLADS contractor accepts suspected or known transformers for disposal as either PCB

contaminated (contains 50 to 500 ppm PCBs) or PCB transformers (contains 500 ppm or

greater PCBs). Light ballasts or capacitors manufactured prior to 1978 are also generally

suspected to be PCB-contaminated, and must be disposed through DLADS. Because it

is neither practical nor cost effective to perform testing on these items, all items not

permanently stamped or marked as “non-PCB” should also be disposed of as PCB-

contaminated through DLADS as a best management practice.

All PCB transformers or other PCB wastes will be stored in a secure area, with adequate

secondary containment, and with proper markings (a PCB label is used when required).

Documentation is maintained on all PCB items in storage. PCB wastes must be in DOT

or UN containers. Transformers, which are generally too large for overpacks, must be

sealed with no leaks. PCB labels must be placed on all PCB containers as well as the

applicable DOT shipping label (Class 9 Miscellaneous, as required by 49 CFR 170-189).

All PCB wastes will be disposed through DLADS using a standard DD Form 1348-1A,

Issue Release/Receipt Document (Appendix H).

11.30 PROCESS PARTICULATES

The aviation maintenance contractor uses Clayton tools for sanding and preparing

various metal pieces as part of processes in multiple facilities, mainly in sheet metal and

paint shops. The Clayton tools are equipped with high efficiency particulate air (HEPA)


11-18

filters and a collection chamber for particulates that are removed during their processes.

The dust and filters generated from these processes should be managed in a HWSAP in

accordance with the procedures in Section 5.

11.31 RATION HEATERS

Organizations should use/activate field ration heaters (FRH) with food during training in

the field. The used FRH can then be placed with regular trash. Unactivated FRH can also

be placed in regular trash containers as long as they are placed individually into the trash

receptacles. Consolidating and discarding multiple FRH is not allowed in regular waste

containers; these must be managed as hazardous waste in a HWSAP in accordance with

the procedures described in Section 5.

Solid fuel used for cooking food, boiling water, or heating MREs, such as trioxane fuel

bars, are lit and burn for several minutes to heat items in the field. These fuel bars are not

as commonly used as the flameless heaters due to safety concerns. Organizations should

completely use the fuel bars for their intended purpose to help prevent generation of this

waste stream. Any solid fuel sources such as this should be accumulated in a HWSAP in

an approved container as described in Section 5.

11.32 SCRAP ITEMS

11.32.1 Scrap Metal All scrap metal should be accumulated in designated areas within the organization’s

operational areas. Any type of scrap metal should be turned in to the Recycling Center

(Building 9322) for recycling. Lead weights may also be recycled as a scrap metal. Scrap

metal should be turned in to the Recycling Center at the roll-off container located behind

the building.

11.32.2 Items Requiring Special Handling The following items cannot be processed as scrap and must be turned in on a separate

DD Form 1348-1A as hazardous or regulated waste since they may contain or be

contaminated with lead deposits, PCBs, or asbestos:

• Fuel tanks

• Asbestos brake shoes, gaskets and clutch plates


11-19

• Undrained hydraulic rams, gas cylinders, and shock absorbers

11.33 SOLDER

Lead and silver solder are used in electronics and avionics shops on the installation to

properly maintain and repair this equipment. Waste solder is collected at each location

and recycled. Call DPW-ENRD recycling program manager who will contact the recycler

who will come and pick it up.

11.34 TONER

Toner is generated during printing operations across the installation. Many of the toner

cartridges that are used in office-type printers are able to be returned to the vendor for

recycling free of charge. Personnel should save toner cartridge shipping boxes and use

them to return the cartridges to the vendor when possible. Toner cartridges that are not

returned to the vendor by the organization should be turned in to the HMCC or the

Recycling Center for recycling.

11.35 USED OIL

Organizations collect used oil (motor oil, hydraulic fluid, brake fluid, transmission fluid,

diesel, and F24) for recycling through a contract administered by the Recycling Center.

For information on collection points and times, contact DPW-ENRD. Containers of used

oil will be marked "USED OIL" and a sign posted stating "Used Oil Only".

All containers must be closed in order to meet ADEM used oil requirements. Any container

equipped with a funnel must have a method to keep the funnel closed that would prevent

a release in the event that the container falls over.

All used oil containers that are 55-gallons or larger are subject to inspection requirements

contained in the SPCC Plan. The SPCC Plan requires weekly inspections of these

containers using USAACE Form 2711, SPCC Container Inspection Checklist. A copy of

this inspection checklist is included in Appendix E.

Used cooking oil is accumulated separately from used petroleum oil in accordance with

the requirements in EMS-WI-SW008, Used Cooking Oil Management.


11-20

11.36 USED OIL FILTERS

Personnel managing metal used oil filters from vehicles where the filter is one quart or

smaller (i.e., spin-on filters) may return the used oil filters to the HMCC directly or place

the used oil filters in designated blue totes for pick up by HMCC delivery personnel. Metal

filters are then drained, crushed and recycled by the generating HMCC. Used oil filters that

have not been punctured or crushed or are being accumulated prior to crushing must be

in containers marked “USED OIL FILTERS”. Containers must be closed except when

adding or removing the filters. Used oil filters must be properly drained then punctured in

the dome and crushed in a suitable machine before placing the filter into collection

containers for scrap metal recycling. Non-metal filters (from all engines except gasoline)

must be drained of free flowing liquid, and then may be disposed in regular trash. All

containers or tanks used to collect and store the used oil drained from filters must be

marked “Used Oil” and managed per current procedures for used oil management.

Additional details about managing used oil filters may be found in EMS-WI-SW007,

Management of Used Oil and Fuel Filters, a copy of which is located in Appendix R.

11.37 WASHRACK SAND/SOIL

Washracks should be managed in accordance with Fort Rucker Regulation 420-14. In the

event that an organization suspects that washrack soil or sand residue contains

hazardous materials, the organization should contact DPW-ENRD and request an

inspection of the soil. DPW-ENRD will provide guidance for the disposal on a case-by-

case basis. Organizations should never allow more than one foot of soil/residue to

accumulate in the traps. This precaution will prevent large volumes of the soil/residue

from possibly becoming contaminated.

11.38 WEAPONS CLEANING MATERIALS

Used weapons cleaning materials include bore patches, Q-tips, and pipe cleaners used

to clean weapons. Personnel should use approved weapon cleaner to clean weapons.

Used cleaning materials should be collected by the organization armorer and stored as

hazardous waste in an approved container in a HWSAP managed in accordance with the

procedures described in Section 5.


11-21

11.39 X-RAY RINSE WATER

Water that is generated as a result of the x-ray developing process is collected for

disposal as hazardous waste for silver contamination. This waste should be managed in

a HWSAP in accordance with the procedures in Section 5.

11.40 ZYGLO RINSATE

Zylgo is used as part of the non-destructive investigation (NDI) process for aircraft

maintenance and repair. The rinsate from this process is a non-hazardous waste that

must be accumulated in a drum for disposal through DLADS. The rinsate should not be

disposed through the wastewater system due to slightly corrosive nature of the waste.


11-22


SECTION TWELVE Spill Response Procedures

12-1

Section 12 Spill Response Procedures

12.1 GENERAL

A spill is the accidental spilling, leaking, pumping, emitting, discharging, emptying or

dumping of hazardous wastes or materials into or on any land or water. All spills are

serious incidents as even a small spill can contaminate millions of gallons of drinking

water. Every soldier, civilian, and contractor is responsible for proper handling of

hazardous materials and wastes, and cleaning any minor spills. The pouring of any

hazardous material on the ground or in a storm drain is illegal and punishable under

civilian laws and the Uniform Code of Military Justice (UCMJ).

12.2 SPILL RESPONSE AND EMERGENCY PROCEDURES

Any person discovering a spill or release of oil or hazardous substances must immediately

report the incident to his/her supervisor. The supervisor will determine if the spill is minor

and should be cleaned up without further notification, or if further notification is required.

If a supervisor cannot be quickly notified or if a major spill threatens personnel safety or

may reach surface waters, storm drains, or sanitary sewer drains, the Fire and

Emergency Services Division (Directorate of Public Safety) must be notified immediately

by calling 911.

The employee or supervisor reporting a spill to the Fire and Emergency Services Division

should provide the following information to the fullest extent known:

1. Location, time, and type of incident (spill, fire, injury, etc.)

2. Name and quantity of spilled material, and the rate of release (an estimate is OK

if not known)

3. Provide a safety data sheet for spilled material if readily available; can be faxed to

the Fire and Emergency Services Division (if it can be done quickly) or provided at

the time of their arrival to the scene

4. Direction of the spill, vapor, or smoke release

5. Fire and/or explosion possibility

6. Coverage area of spill, and intensity of any fire or explosion (if applicable)

7. The extent of injuries (if any)


12-2

As part of the existing notification procedures, the Fire and Emergency Services Division

will always notify DPW-ENRD so there is no need for the reporter of the spill to place a

second call to DPW-ENRD once the Fire and Emergency Services Division has been

notified.

When the Fire and Emergency Services Division has determined that there is no longer

a threat to life or property, DPW-ENRD will serve as the on-scene coordinator and will

determine if the spill is reportable to others as required by the ISCP. Cleanup assistance

and remediation of the site (if necessary) will be provided by the installation maintenance

support contractor. The organization responsible for the spill will be billed later for any

cleanup or remediation expenses.

The organization responsible for the spill or release must complete a written spill report

and email or fax it to DPW-ENRD at [email protected] or (334) 255-2058 within

five days of the incident (USAACE Form 2718, Spill Notification Form).

12.3 SPILL CONTINGENCY PLANS

The Fort Rucker SPCC Plan and ISCP are required reading for all personnel who manage

or supervise hazardous waste activities and for all organization emergency response

coordinators. Copies of both of these plans are available on the Sustainable Fort Rucker

website.

Each organization generating or storing hazardous waste shall prepare and possess a

hard copy of the organization’s Site Specific Spill Plan for waste handling and storage

areas using USAACE Form 2719, Site Specific Spill Plan. A copy of the form is located

in Appendix T. The plan shall be designed to minimize hazards to human health and the

environment from fires, explosions, and any unplanned releases of hazardous

constituents to the air, soil, or surface water. The provisions of the plan shall be carried

out whenever there is a fire, explosion, or release of hazardous waste or constituents

which could threaten human health or the environment.

All organization personnel who manage or handle hazardous wastes shall read and

understand all procedures contained in the Site Specific Spill Plan, and shall receive initial

training and annual update training in executing the procedures as they pertain to their


12-3

positions. A copy of the Site Specific Spill Plan will be maintained at all organization waste

generation, management, and storage areas. The plan will be reviewed annually and

amended whenever:

a. The plan fails in an emergency.

b. The facility changes design, construction, operation, location, procedures, or other

circumstances that require changes in established emergency response

procedures.

c. The organization emergency coordinator and/or emergency equipment changes.

12.4 SPILL CONTINGENCY TRAINING

At least once per year, all organizations (including contractors) must provide initial or

update training for all employees who handle or use hazardous materials, hazardous

waste, and/or oil/fuel of any type in quantities equal to or greater than one quart at a time

(this requirement does not include refueling a ground vehicle at a fuel pump). New

employees must not be allowed to perform any operations involving hazardous materials,

hazardous waste, or oil/fuel without direct supervision until they receive training. Training

will, at a minimum, cover the following subjects:

• ISCP requirements

• General requirements of the SPCC Plan

• Container-specific requirements of the SPCC Plan applicable to their assignments

12.5 SPILL CONTINGENCY SUPPLIES

All organizations must maintain adequate stocks of spill control supplies and equipment

to handle spills. Spill contingency supplies are available at the HMCC and through

commercial catalogs. These supplies include dry sweep and absorbent pads and booms

at a minimum. Organizations should use absorbents that are part of the continued use

program whenever possible. Additional details about requirements for spill contingency

supplies are included in the ISCP.

12.6 SPILL REPORTING

In addition to the reporting that is required for implementation of the contingency plan,

spills of hazardous waste that exceed the reportable quantity must be reported to


12-4

appropriate agencies, including the National Response Center (NRC), EPA, and ADEM.

The ISCP and the SPCC Plan discuss the details of the required notifications when a

release occurs. DPW-ENRD is responsible for reporting to the State in the event of a spill.

The Fort Rucker Fire Department is responsible for any reporting to the NRC. Any reports

to these agencies must be coordinated through DPW-ENRD.

Appendix A Waste Disposal Data CY10-CY15

REGULATED WASTE CY10 CY11 CY12 CY13 CY14 CY15Absorbent Materials - Contaminated with Cadmium, Chromium, and/or Lead 36,402 22,388 19,368 18,206 14,193 10,531

Absorbent Materials/Filters - Contaminated with Paint 28,340 16,926 18,838 16,730 17,361 10,242

Paint and Thinner 15,305 11,892 8,375 8,797 7,932 6,020Abrasive Blast Media 11,245 4,760 5,125 9,420 8,940 3,364Clarus Parts Washer Liquid 10,477 6,738 7,532 4,621 6,339 4,591Petroleum Lab Waste (Heptane/Toluene) 5,569 4,966 6,854 5,065 3,755 3,925Other Paint and Related Materials 0 0 0 0 0 1,796Acids 410 377 71 13 21 72Clarus Parts Washer Filters 86 148 258 233 484 245Fixer/Developer 4,820 660 0 0 0 0Caustic Cleaning Compounds 0 0 2,605 284 227 27Plating Shop Solids 1,235 1,844 3,580 2,350 2,610 730Expired Adhesives 257 373 382 0 71 133Expired Corrosive Chemicals 0 609 0 0 0 47Crushed/Broken Bulbs 16 470 5 491 326 349Carbon Remover 829 0 0 0 0 750Chemical Defense Equipment (CDE) 0 0 509 392 71 0Alodine Waste 177 0 0 0 0 150Expired Military Equipment 0 1,005 0 0 0 191Oxidizing Materials 0 23 0 0 0 36Aerosols 332 103 87 80 167 245Lead Based Paint and Debris 0 0 10,888 673 0 94Other Waste from Aircraft Maintenance 297 2,607 926 0 0 617Denatured Alcohol (noncompliant) 703 0 0 56 61 0Medical Waste 146 99 154 0 0 378TOTAL (LBS) 116,646 75,988 85,557 67,411 62,558 45,636*TOTAL (TONS) 58 38 43 34 31 23*Includes 1,103 lbs. one-time waste

UNIVERSAL WASTE CY10 CY11 CY12 CY13 CY14 CY15Batteries (Ni-Cad and Lithium) 2,033 801 1,066 1,088 9,036 1,122Fluorescent Lamps 8,538 7,541 6,125 5,915 6,976 6,726TOTAL (LBS) 10,571 8,342 7,191 7,003 16,012 7,848TOTAL (TONS) 5 4 4 4 8 4

Waste Disposal Data

Appendix B USAACE Form 2735, Hazardous Waste Job Description and Training

Record

HAZARDOUS WASTE MANAGEMENT JOB DESCRIPTION AND TRAINING RECORD For use of this form, see the Hazardous Waste Management Plan; the proponent is DPW-ENRD

USAACE FORM 2735, rev 23MAY11 Page 1 of 3 THIS IS A CONTROLLED DOCUMENT. REPLACES EMS-F035, WHICH IS OBSOLETE VERIFY MOST RECENT VERSION ONLINE.

Under penalty of federal and state laws, job descriptions and training documentation relating to hazardous waste management must be kept on file for all personnel on Fort Rucker that collect, process, treat, dispose, recover, transport, or store hazardous waste. The following form is provided to assist in compliance with the above stated laws. Location of filing for this form is at the discretion of the commander/ supervisor but must be available for inspections by the Alabama Department of Environmental Management (ADEM), Environmental Protection Agency (EPA), and DPW-ENRD.

NAME

ORGANIZATION JOB TITLE JOB DESCRIPTION (As related to hazardous waste management only) Personnel job position relating to hazardous waste management includes: Handling/disposing/storing/ transporting hazardous waste generated by one or more of the following: (check applicable portions below):

Aviation Maintenance

Motorpool Maintenance

Adhesives, Sealants and Paints

Arms Room

Use of Cleaning Solvents

Medical/Dental Operations

Photographic Developing Laboratories or Printing Facilities

Laboratory Operations

Batteries (including Lithium, Magnesium, Mercury, Nickel-Cadmium, & Lead Acid)

Pesticides, Insecticides, Rodenticides, Herbicides, Fungicides

Nuclear, Biological, and Chemical (NBC) Material

Other:

DUTIES (As related to hazardous waste management only) DATE ASSUMED DUTIES: The above person’s duties have a direct effect on hazardous waste management and/or hazardous waste accumulation, whether by direct contact with the hazardous waste or through hazardous waste management activities, must receive training. This individual has the appropriate qualifications to read, understand, apply, and communicate written and verbal information regarding handling and managing hazardous wastes. Responsibilities include:

90-Day HWAS Manager HWSAP Manager Environmental Officer EPOC HW Handling

Placing HW in HWSAP Documenting HW Activities Receiving HW

Transporting HW

Inspecting HWSAP

Inspecting 90-Day HWAS

Emergency Response

TRAINING (As related to hazardous waste management only) Personnel must receive hazardous waste management training within six months of assumption of duties involving hazardous waste. Personnel may not perform hazardous waste management duties unsupervised until completion of training. The training program must be directed by a person trained in hazardous waste management procedures, and must include instruction which teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions in which they are employed. All personnel trained must complete an annual review of the initial training. At a minimum, the training program must be designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including where applicable:

1. Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment; 2. Key parameters for automatic waste feed cut-off systems; 3. Communications or alarm systems; 4. Response to fires or explosions; 5. Response to groundwater contamination incidents; and 6. Shutdown of operations.



NAME Defense Hazardous Materials/ Hazardous Waste Handling Class – Provided by: ALMC

Initial Training (24 hrs) Date:

Annual Refresher Training (8 hrs) Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

On-the-Job Training – Provided by: Initial Training Date:

Annual Refresher Training Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date: Hazardous Waste Satellite Accumulation Point Manager Training – Provided by: DPW-ENRD Initial Training (2 hrs) Date:


Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date:



NAME 90-Day Hazardous Waste Accumulation Site Manager Training – Provided by: DPW-ENRD Initial Training (2 hrs) Date:


Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date: Environmental Officer Training – Provided by: DPW-ENRD



Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date: Environmental Point of Contact (EPOC) Training – Provided by: DPW-ENRD


Annual Refresher Training (4hrs) Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Date: Date: Date:

Appendix C USAACE Form 2729, EO/EPOC Appointment Memo

ENVIRONMENTAL OFFICER / ENVIRONMENTAL POINT OF CONTACT APPOINTMENT MEMO

For use of this form, see GC Policy Memo 13-35; the proponent is DPW-ENRD

USAACE FORM 2729, rev 28FEB13 Page 1 of 2 THIS IS A CONTROLLED DOCUMENT. PREVIOUS EDITIONS ARE OBSOLETE VERIFY MOST RECENT VERSION ONLINE.

(office symbol)

(date)

MEMORANDUM FOR SEE DISTRIBUTION SUBJECT: Environmental Officer or Environmental Point of Contact (EPOC) Appointment 1. The individuals listed in the attached table are appointed as the Environmental Officer or EPOC for their assigned work areas. 2. Authority for this appointment is Army Regulation 200-1, paragraphs 1-27.a.(15) and 1-32.f., which require installation and tenant commanders/directors to appoint and train Environmental Officers at appropriate organizational levels to ensure required environmental actions are taking place. Appropriate levels of appointment are discussed in the Environmental Officer and EPOC Appointment and Training Plan. 3. Purpose: To perform duties as Environmental Officer or EPOC. 4. Period: Until reassigned or relieved of these duties. 5. Special Instructions: Appointees must attend the Environmental Officer or EPOC Course (as appropriate to duties) within six months after being appointed and attend an annual refresher thereafter. POC NAME: PHONE:

COMMENTS:

(signature block)(signature block)(signature block)

DISTRIBUTION: ORGANIZATION COMMANDER/DIRECTOR CURRENT ENVIRONMENTAL OFFICER/EPOC NEWLY APPOINTED INDIVIDUAL DPW-ENRD (ATTN Ms. Melissa Lowlavar, [email protected])

ENVIRONMENTAL OFFICER / ENVIRONMENTAL POINT OF CONTACT APPOINTMENT MEMO

For use of this form, see GC Policy Memo 13-35; the proponent is DPW-ENRD

USAACE FORM 2729, rev 28FEB13 Page 2 of 2 THIS IS A CONTROLLED DOCUMENT. PREVIOUS EDITIONS ARE OBSOLETE VERIFY MOST RECENT VERSION ONLINE.

NAME EO or EPOC EMAIL LOCATION

*NOTE: Organizations may substitute an organization-generated table containing at least the information specified in this template. Attach additional pages as necessary.

Appendix D USAACE Form 2733, HWSAP and 90-Day HWAS Manager

Appointment Memo

HAZARDOUS WASTE SATELLITE ACCUMULATION POINT (HWSAP) OR 90-DAY HAZARDOUS

WASTE ACCUMULATION SITE (90-HWAS) MANAGER APPOINTMENT MEMO For use of this form, see the Hazardous Waste Management Plan; the proponent is DPW-ENRD

USAACE FORM 2733, rev 28SEP12 Page 1 THIS IS A CONTROLLED DOCUMENT. PREVIOUS EDITIONS ARE OBSOLETE VERIFY MOST RECENT VERSION ONLINE.

(office symbol)

(date)

MEMORANDUM FOR SEE DISTRIBUTION SUBJECT: HWSAP or 90-HWAS Manager Appointment 1. The individuals listed in the attached table are appointed as the HWSAP or 90-HWAS Managers for their assigned work areas. 2. Authority for this appointment is the Hazardous Waste Management Plan (HWMP) Section 3, which requires appointment of a HWSAP and 90-HWAS manager for each HWSAP and 90-HWAS location on Fort Rucker. The requirement to have a HWMP is included in AR 200-1 Section 10-1d(3). 3. Purpose: To perform duties as HWSAP or 90-HWAS Manager as specified in the HWMP. 4. Period: Until reassigned or relieved of these duties. 5. Special Instructions: Appointees must attend the HWSAP Manager or 90-HWAS Manager Course (as appropriate to duties) within six months after being appointed and attend an annual refresher thereafter.

POC NAME: PHONE: COMMENTS:

(signature block)

(signature block)

DISTRIBUTION: ORGANIZATION COMMANDER/DIRECTOR CURRENT MANAGER NEWLY APPOINTED INDIVIDUAL DPW-ENRD (ATTN Ms. Colleen Quinlan, [email protected])

USAACE FORM 2733, rev 28SEP12 Attachment 1 THIS IS A CONTROLLED DOCUMENT. PREVIOUS EDITIONS ARE OBSOLETE VERIFY MOST RECENT VERSION ONLINE.

Name HWSAP or 90-HWAS

Primary or Alternate Phone Location Person Replaced

*NOTE: Organizations may substitute an organization-generated table containing at least the information specified in this template. Attach additional pages as necessary. Indicate N/A in the line for person replaced if the individual is not replacing someone else with this appointment.

Appendix E Inspection Forms

USAACE Form 2725, HWSAP Inspection Checklist USAACE Form 2726, 90-HWAS Inspection Log

USAACE Form 2711, SPCC Plan Container Inspection Form

USAACE Form 2717, Environmental Compliance Inspection Checklist

SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN CONTAINER INSPECTION CHECKLISTFor use of this form, see the SPCC Plan; the proponent is DPW-ENRD

Inspector:

Number of Containers:

Date of Inspection:CONTAINER

YES NO N/A YES NO N/A YES NO N/A YES NO N/A YES NO N/A

SECONDARY CONTAINMENT

Secondary Containment Type:

YES NO N/A YES NO N/A YES NO N/A YES NO N/A YES NO N/A

COMMENTS

Organization:

Choose the Container ID from the pull down list.

Container Type:

Location:

CONTAINER IDCONTAINER ID CONTAINER ID CONTAINER ID CONTAINER ID

Is coating in good condition?

Are gauges present and functioning properly for main container?

Are gauges present and functioning properly for interstitial space of double-walled container?

Is container in good condition (no holes, rust, dents, leaks, etc.)?

Is piping in good condition (no holes, rust, dents, leaks, etc.)?

Is container clearly labeled as to content?

Is capacity of the container clearly labeled?

Have spills been cleaned (i.e., no visible oil/product near container, on container surface, or in secondary containment)?

Are valves, fill ports, lids and any other openings sealed/closed when not in use?

Material Stored:

Container Purpose:

Are emergency release valves present and operational?

Turn in completed forms to Melissa Lowlavar in bldg 1121 or email to [email protected]

NOTE: Structrual containment includes buildings, dikes, berms, etc. If no secondary containment is present, notify DPW-ENRD.

If rainwater collects in secondary containment, is it inspected for contamination and properly discharged at least weekly?

Is secondary containment valve kept closed?

Is secondary containment sufficiently impervious to contain spills/leaks (i.e., no cracks, visible vegetation, etc.)?

Are spill response supplies (i.e., absorbents, spill kits) available in sufficient quantities?

Note: Any deficiencies should be corrected immediately if possible (i.e., spills, open containers, etc.). Items requiring a work order for repair should be identified in this section with work order numbers.

Is secondary containment checked and found to be free of material?

Double-walled

Structural None

Double-walled

Structural None

Double-walled

Structural None

Double-walled

Structural None

Double-walled

Structural None

USAACE FORM 2711 (rev 31MAR15) PREVIOUS EDITION IS OBSOLETE

THIS IS A CONTROLLED DOCUMENT. VERIFY THE LATEST VERSION ONLINE.

SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN CONTAINER INSPECTION CHECKLISTFor use of this form, see the SPCC Plan; the proponent is DPW-ENRD

Container Type:

Container Purpose:

Inspection Date:CONTAINER

YES NO N/A YES NO N/A YES NO N/A YES NO N/A YES NO N/A YES NO N/A

SECONDARY CONTAINMENTSecondary Containment Type:

YES NO N/A YES NO N/A YES NO N/A YES NO N/A YES NO N/A YES NO N/A

Is secondary containment checked and found to be free of material?

COMMENTS

Organization:

Turn in completed forms to Melissa Lowlavar in bldg 1121 or email to [email protected]

NOTE: Structrual containment includes buildings, dikes, berms, etc. If no secondary containment is present, notify DPW-ENRD.

If rainwater collects in secondary containment, is it inspected for contamination and properly discharged at least weekly?

Is secondary containment valve kept closed?

Is secondary containment sufficiently impervious to contain spills/leaks (i.e., no cracks, visible vegetation, etc.)?

Are spill response supplies (i.e., absorbents, spill kits) available in sufficient quantities?

Note: Any deficiencies should be corrected immediately if possible (i.e., spills, open containers, etc.). Any items that require a work order for repair should be identified in this comment section with applicable work order numbers.

Have spills been cleaned (i.e., no visible oil/product near the container, on the container surface, or in secondary containment)?

Are valves, fill ports, lids and any other openings sealed/closed when not in use?

Are gauges present and functioning properly for main container?

Are gauges present and functioning properly for interstitial space of double-walled container?

Are emergency release valves present and operational?

Is container in good condition (no holes, rust, dents, leaks, etc.)?

Is piping in good condition (no holes, rust, dents, leaks, etc.)?

Is container clearly labeled as to content?

Is capacity of the container clearly labeled?

Is coating in good condition?

CONTAINER ID CONTAINER ID CONTAINER ID CONTAINER ID CONTAINER ID CONTAINER ID

DPW ID DPW IDInspector:

Choose the DPW ID from the pull down list. DPW ID DPW ID DPW ID DPW ID

AST Belly Tank

Fire PumpGEN

Double-walled

Structural None

Double-walled

Structural None

Double-walled

Structural None

Double-walled

Structural None

Double-walled

Structural None

Double-walled

Structural None

AST Belly Tank

Fire PumpGEN

AST Belly Tank

Fire PumpGEN

AST Belly Tank

Fire PumpGEN

AST Belly Tank

Fire PumpGEN

AST Belly Tank

Fire PumpGEN


THIS IS A CONTROLLED DOCUMENT. VERIFY THE LATEST VERSION ONLINE.

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HAZARDOUS WASTE SATELLITE ACCUMULATION POINT INSPECTION CHECKLISTFor use of this form, see the Hazardous Waste Management Plan; the proponent is DPW-ENRD

Date: Date: Date: Date: Date:Initials: Initials: Initials: Initials: Initials:

1)2)3)4)

5)

6)7)

1)

2)

1)2)3)

4)

5)6)

7)

1)

2)

MONTH:

NOTES (unsatisfactory observations, explanations and corrections to be noted with date and corrective actions taken.)

Employee training records are maintained, readily accessible, and documented on USAACE Form 2735

Facility personnel are trained in HW handling and emergency response

C. PREPAREDNESS & PREVENTION

Spill control equipment is availableFire control equipment is availableCommunication equipment is available and working

B. ACCUMULATION TIME

√ -- If satisfactory U – If unsatisfactory

A. CONTAINER MANAGEMENT

HW is under the control of the generatorHW is collected at or near the point of generation

Aisles are clear for emergency evacuationThe equipment listed above is maintained

Decontamination equipment (e.g. shower, eye wash) is available

D. PERSONNEL TRAINING

A Site Specific Spill Plan and ISCP exists for facility and signage indicates emergency contact

WEEK 5WEEK 2 WEEK 3 WEEK 4LOCATION:

Containers are closed

Full containers dated less than three days old

55-gallons or less of each HW stream is stored in the designated area (or 1-quart of “P” listed waste)

INSPECTOR (Alt):PHONE NO:INSPECTOR: WEEK 1

All HW containers are properly marked “Hazardous Waste” with contents and waste code(s)

Incompatible wastes are segregated

Wastes are in compatible containersContainers are in good condition (no damage or leaks)

USAACE FORM 2725 (rev 17DEC13)PREVIOUS EDITIONS ARE OBSOLETE

THIS IS A CONTROLLED DOCUMENT.VERIFY MOST RECENT VERSION ONLINE.

90-DAY HAZARDOUS WASTE ACCUMULATION SITE (90-HWAS) INSPECTION LOGFor use of this form, see the Hazardous Waste Management Plan; the proponent is DPW-ENRD

DATE: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

TIME:

Site-Specific Spill Plan and ISCP readily available

Containers are less than 60 days old

HW accumulation start dates are noted

Containers are properly labeled (including EPA ID #)

Incompatible wastes are separated

Month Building FORT RUCKERYear

No evidence of leaks or spills

Containment Area - no holes or cracks

Wastes are compatible with containers

Containers are closed and free from leaks, rust or dents

INSPECTOR'S NAME(S) √ -- If Satisfactory U – If Unsatisfactory

HW storage area is secured to prevent unauthorized entry

INSPECTOR (INITIALS):

Number/capacity of containers noted

Adequate aisle space

Warning signs posted

Communication system (e.g. phone, alarm) active

Portable fire extinguisher on hand

Spill control equipment on hand

Training records complete and available

SPCC Plan readily available

Annotate corrective action(s) taken and date:

Note unsatisfactory observations and explain:

USAACE FORM 2726 (rev 23 MAY11)REPLACES EMS-F026, WHICH IS OBSOLETE

THIS IS A CONTROLLED DOCUMENT.VERIFY MOST RECENT VERSION ONLINE.

Appendix F ADEM Letters and Guidance

Alabama Department of Environmental Management Land Division P. O. Box 301463 Montgomery, AL 36130-1463 Telephone 334-271-7730 Fax 334-279-3050

January 2014

Hazardous Waste Management

Management of Aerosol Containers

Information presented in this fact sheet is intended to provide a general understanding of the regulatory requirements governing the management of disposable aerosol containers. This information

is not intended to replace, limit, or expand upon the complete regulatory requirements found in Division 14 of the Alabama Department of Environmental Management Administrative Code.

WHAT IS AN AEROSOL CONTAINER?

An aerosol container is a dispenser that holds a substance under pressure and that can release the substance,

usually by means of a propellant gas, in a number of forms such as wet sprays, fine sprays, powder sprays, foams,

or pastes. Common liquefied propellants include propane, butane, and isobutane.

WHAT ARE THE SAFETY AND ENVIRONMENTAL CONCERNS FOR AEROSOL CONTAINERS?

Some aerosol products (for example, paints, solvents, and pesticides) are hazardous due to the presence of

hazardous ingredients. Aerosol products should be used with adequate ventilation and/or personal protective

equipment to prevent inhalation and exposure that may result in harmful health effects. Extreme temperatures may

cause containers to rupture and moisture may cause them to rust, resulting in a release of the contents to the

environment. Many aerosol containers pose a fire hazard because they contain highly flammable propellants such

as propane and butane. Pressurized containers present additional concerns. If punctured, the contents may be

released so forcefully that injuries can result. Also, pressurized containers delivered to a landfill present safety

concerns during compacting.

Spent Aerosol Can Management

I will RECYCLE my cans.

Are the cans empty?

Yes:

Empty aerosol cans being

recycled are excluded from

management as solid (and

therefore hazardous) waste.

[See 335-14-2-.01(4)(a)13.]

No:

Cans may be recycled, but the

contents are solid wastes

subject to a hazardous waste

determination. Any liquids or

propellants removed from the

cans must be managed in

accordance with ADEM div.

14 requirements.

[See 335-14-2-.01(6)(a)3.(ii)

and 335-14-3-.01(2)]

How will you manage your spent

aerosol cans?

I will DISPOSE my cans.

Are the cans empty?

Yes:

Aerosol cans that are empty and

fully depressurized may be

disposed of as solid waste,

which are subject to a hazardous

waste determination.

[See 335-14-2-.01(7) and

335-14-3-.01(2)]

No:

A discarded aerosol can is a

hazardous waste if the can and

its contents exhibit a hazardous

waste characteristic or if it is a

listed hazardous waste.

[See 335-14-3-.01(2)]

“Empty” means the aerosol can does not contain a significant amount of free liquid and also that the propellant

has been used up so that the pressure in the can is at or near atmospheric pressure. This can usually be determined

during the normal use of the product in the manner it was intended to be used. If you cannot demonstrate that the

can is empty then it must be emptied by the means ordinarily used to render aerosol cans empty (e.g. the can must

be punctured, crushed, or shredded and in the process the gas and the liquid must be contained/captured and

Disposable Aerosol Containers

Page 2 of 3

managed appropriately). If your aerosol can held an acute hazardous waste it must be triple rinsed to be

considered “empty”. [See 335-14-2-.01(7)]

WHAT IS THE PREFERRED MANAGEMENT METHOD FOR AEROSOL CONTAINERS?

•••• Empty the container, either through normal use or by puncturing and draining.

•••• When puncturing a container, collect both the liquid and the gas in an appropriate collection device.

•••• Send the empty container to a scrap metal recycler.

•••• Dispose of the collected residues appropriately, based on their regulatory status - either as solid or

hazardous waste.

While landfill disposal of the empty containers is an acceptable alternative, it is the least preferred option.

MAY I USE A DEVICE TO PUNCTURE AEROSOL CONTAINERS?

Companies that regularly generate significant numbers of waste aerosol containers may be interested in using a

device to puncture and drain the containers. Punctured, drained aerosol containers are known as “processed scrap

metal”, which is exempt from the solid waste regulations so long as it is recycled. Use of such a device does not

require a waste-treatment permit at this time. If you choose to use one, consider the following precautions:

• Do not puncture containers with any of these ingredients: ethyl ether (often in starting fluids), chlorinated

compounds, pesticides, freons and foamers, oven cleaners, unknowns. These should be lab-packed and

managed as hazardous waste.

• Follow the manufacturer’s instructions for operating, cleaning, and maintaining the device.

• Employees operating the device should be thoroughly trained in its use and should wear appropriate

personal protective equipment.

• Sort containers by size and puncture similar sizes at the same time. You may wish to puncture containers

with solvents, degreasers, and/or lubricants last to help clean the device.

• Operate only in an open, well-ventilated area. Avoid confined spaces.

• Collect liquids in an appropriate hazardous waste container.

• Keep the unit closed when it is not in use.

• Puncturing spent aerosol cans for recycling is considered a form of treatment under ADEM Admin. Code r.

335-14-8-.01(1)(c)2.(x). According to that rule, you do not need a permit, but you must notify the

Department at least 60 days in writing before you begin puncturing cans.

HOW SHOULD I MANAGE AEROSOL CONTAINERS THAN CANNOT BE EMPTIED?

•••• First try to return or exchange malfunctioning aerosol containers. Malfunctioning aerosol containers

returned to the supplier or manufacturer are considered “products”, not “wastes”.

•••• Non-empty aerosol containers that cannot be returned or exchanged must usually be managed as a

hazardous waste, depending on the specific contents (including propellants, which are often flammable).

HOW CAN I REDUCE MY AEROSOL CONTAINER WASTE?

� Determine whether or not a product is needed. Could the process using the aerosol be eliminated?

� Could a non-aerosol product be used instead of the aerosol product?

� If required, choose a non-hazardous product, or the least hazardous product, that will do the job.

� Use only as much as is needed.

� Store aerosol containers away from moisture, sunlight, and extreme heat or cold.

� Follow the label instructions to clean the nozzle after each use.

� Use the entire contents of a container before buying more.

� Purchase according to demand so that the product’s shelf life does not expire.

� Consider purchasing products in bulk and using either a refillable container with compressed air as the

propellant or a non-aerosol pump applicator.

Disposable Aerosol Containers

Page 3 of 3

WHERE CAN I GET ADDITIONAL INFORMATION?

ADEM Administrative Code rules (ADEM Admin. Code rs)

provide more in-depth information regarding the status of metal that will be recycled.

335-14-2-.01(7) provides a full definition of “RCRA Empty containers”, while “processed scrap metal” is defined

at ADEM Admin. Code r. 335-14-1-.02(1)(a)208.

On-Line Resources

Earth 911 - http://earth911.com

ADEM Home Page - http://www.adem.alabama.gov

ADEM Administrative Code Division 14

ADEM Guidance - http://www.adem.alabama.gov/programs/land/guidanceReports.cnt

Hazardous Waste Determination

Hazardous Waste: The Basics

Notification of Regulated Waste Activity

ADEM Publications - http://www.adem.alabama.gov/MoreInfo/publications.cnt

RCRA Small Quantity Generator Handbook

US Environmental Protection Agency’s Homepage

Telephone Resources

ADEM Ombudsman

Hazardous Waste Compliance Inspectors

*Adapted from the following sources: Oregon Department of Environmental Quality Program Implementation Guidance Number 2005

Nebraska Department of Environmental Quality Environmental Guidance

WHERE CAN I GET ADDITIONAL INFORMATION?

(ADEM Admin. Code rs) 335-14-2-.01(4)(a)13. and 335

depth information regarding the status of metal that will be recycled. ADEM Admin. Code r.

.01(7) provides a full definition of “RCRA Empty containers”, while “processed scrap metal” is defined

.02(1)(a)208.

http://www.adem.alabama.gov

ADEM Administrative Code Division 14 - http://www.adem.state.al.us/alEnviroRegLaws/files/Division14.pdf

http://www.adem.alabama.gov/programs/land/guidanceReports.cnt

Notification of Regulated Waste Activity

http://www.adem.alabama.gov/MoreInfo/publications.cnt :

Quantity Generator Handbook

US Environmental Protection Agency’s Homepage - http://www.epa.gov

Telephone Resources

ADEM Ombudsman - - - - - - - - - - - - - - - - - - - 800-533- 2336

Hazardous Waste Compliance Inspectors - - - 334-271-7730

*Adapted from the following sources: Oregon Department of Environmental Quality Program Implementation Guidance Number 2005

Nebraska Department of Environmental Quality Environmental Guidance Document 03-067, dated December 2003.

.01(4)(a)13. and 335-14-2-.01(6)(a)3.(ii)

ADEM Admin. Code r.

.01(7) provides a full definition of “RCRA Empty containers”, while “processed scrap metal” is defined

http://www.adem.state.al.us/alEnviroRegLaws/files/Division14.pdf

2336

7730

*Adapted from the following sources: Oregon Department of Environmental Quality Program Implementation Guidance Number 2005-PO-001 (dated 07/24/2005);

Appendix G USAACE Form 2716, Secondary Containment Drainage Activity Log

Location

DATE START TIME END TIME

FREE OF SHEEN OR OTHER

MATERIAL/ WASTE?*

NAME

SECONDARY CONTAINMENT DRAINING ACTIVITY LOG

For use of this form, see the Spill Prevention, Control, and Countermeasures (SPCC) Plan; the proponent is DPW-ENRD

*NOTE: If a sheen is present, contact the Environmental Office at 255-1657 for further information.

NEVER DISCHARGE ANY WATER WITH A SHEEN OR EVIDENCE OF ANY HAZARDOUS MATERIAL OR

HAZARDOUS WASTE. THE DISCHARGE OF WATER WITH A SHEEN OR OTHER CONTAMINATION MAY LEAD

TO A VIOLATION OF THE FORT RUCKER STORMWATER DISCHARGE PERMIT.


THIS IS A CONTROLLED DOCUMENT.VERIFY THE LATEST VERSION ONLINE.

Appendix H DD Form 1348-1A, Issue Release/Receipt Document

2 3 4 5 6 7 2 2 2 2 2 2 2 4 4 4 4 4 5 5 5 5 5 5 5 5 5 5 6 6 6 6 6 6 6 6 6 6 7 7 7 7 7 7 7 7 7 7

8 1. TOTAL PRICE 2. SHIP FROM 3. SHIP TO

3 4 5 6 7 8 9 5 6 7 8 9 0 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 7 8 9 0

RI M U I QUANTITY SUPPLE- S F DIS- PR0- P R D D A RI O C M UNIT PRICE D OLLARS CTS

FROM & N S S MENTARY I U TRI- JECT R E E A D / O G

S I S E ADDRESS G N BU- I Q L T V P N T DOLLA RS CTS

T R D TION D E D $

$ 4. MARK FOR

24. DOCUMENT NUMBER & SUFFIX (30-44) 5. DOC DATE 6. NMFC 7. FRT RATE 8. TYPE CARGO 9. PS

DOC:

DOT SHIPPING NAME:

10. QTY. REC’D 11. UP 12. UNIT WEIGHT 13. UNIT CUBE 14. UFC 15. SL

25. NATIONAL STOCK NO & ADD (8-22) NSN:

lbs

16. FREIGHT : See below

BILL TO: 17. ITEM

LOCATION: 18. TY CONT 19. NO CONT 20. TOTAL

WEIGHT 21. TOTAL CUBE

1 LBS 22. RECEIVED BY 23. DATE RECEIVED 26. RIC(4-6), UI(23-24), QTY(25-29), CON CODE(71), COG(55-56), UP(74-80) Return Part 2 to:

27. ADDITIONAL DATA POC: WASTE CODES:

CLIN: DISPOSAL COST: $

TOTAL COST: $

The above name materials are properly classified, described, packaged, marked, and labeled and are in proper condition for transportation according to the applicable regulations of the Department of Transportation (49 CFR 170-189)

PROFILE NUMBER: CERTIFIED BY:(SIGN) (PRINT)

ASD: EPA ID:

INSPECTED BY: (SIGN) (PRINT) DD FORM 1348-1A, JAN 96 ISSUE RELEASE/RECEIPT DOCUMENT FORM APPROVED, OMB NO 0704-0188

Appendix I 49 CFR 172.400 Excerpt

399

Pipeline and Haz. Matls. Safety Admin., DOT § 172.400

Packaging: When: Then the alter-native marking re-quirement is:

On one end of nurse tanks if that end con-tains valves, fit-tings, regulators or gauges when those appur-tenances pre-vent the mark-ings and placard from being prop-erly placed and visible.

They meet the provisions of § 173.315(m) of this subchapter.

N/A.

On cargo tanks, in-cluding compart-mented cargo tanks, or tank cars.

They contain more than one petro-leum distillate fuel.

The identification number for the liquid petroleum distillate fuel having the low-est flash point is displayed. If the cargo tank also contains gaso-line and alcohol fuel blends con-sisting of more than 10% eth-anol the identi-fication number ‘‘3475’’ or ‘‘1987,’’ as ap-propriate, must also be dis-played.

(d) When a bulk packaging is labeled

instead of placarded in accordance with

§ 172.514(c) of this subchapter, identi-

fication number markings may be dis-

played on the package in accordance

with the marking requirements of

§ 172.301(a)(1) of this subchapter.

[Amdt. 172–101, 45 FR 74667, Nov. 10, 1980, as

amended by Amdt. 172–74, 47 FR 40365, Sept.

30, 1982; Amdt. 172–109, 52 FR 13038, Apr. 20,

1987; Amdt. 172–110, 52 FR 29528, Aug. 10, 1987;

Amdt. 172–123, 55 FR 52593, Dec. 21, 1990; 56

FR 66255, Dec. 20, 1991; 65 FR 50459, Aug. 18,

2000; 73 FR 4716, Jan. 28, 2008; 76 FR 43527,

July 20, 2011; 78 FR 14714, Mar. 7, 2013; 78 FR

65478, Oct. 31, 2013]

§ 172.338 Replacement of identification numbers.

If more than one of the identification

number markings on placards, orange

panels, or white square-on-point dis-

play configurations that are required

to be displayed are lost, damaged or de-

stroyed during transportation, the car-

rier shall replace all the missing or

damaged identification numbers as

soon as practicable. However, in such a

case, the numbers may be entered by

hand on the appropriate placard, or-

ange panel or white square-on-point

display configuration providing the

correct identification numbers are en-

tered legibly using an indelible mark-

ing material. When entered by hand,

the identification numbers must be lo-

cated in the white display area speci-

fied in § 172.332. This section does not

preclude required compliance with the

placarding requirements of subpart F

of this subchapter.

[Amdt. 172–110, 52 FR 29528, Aug. 10, 1987]

Subpart E—Labeling

§ 172.400 General labeling require-ments.

(a) Except as specified in § 172.400a,

each person who offers for transpor-

tation or transports a hazardous mate-

rial in any of the following packages or

containment devices, shall label the

package or containment device with la-

bels specified for the material in the

§ 172.101 table and in this subpart:

(1) A non-bulk package;

(2) A bulk packaging, other than a

cargo tank, portable tank, or tank car,

with a volumetric capacity of less than

18 m3 (640 cubic feet), unless placarded

in accordance with subpart F of this

part;

(3) A portable tank of less than 3785 L

(1000 gallons) capacity, unless plac-

arded in accordance with subpart F of

this part;

(4) A DOT Specification 106 or 110

multi-unit tank car tank, unless plac-

arded in accordance with subpart F of

this part; and

(5) An overpack, freight container or

unit load device, of less than 18 m3 (640

cubic feet), which contains a package

for which labels are required, unless

placarded or marked in accordance

with § 172.512 of this part.

(b) Labeling is required for a haz-

ardous material which meets one or

more hazard class definitions, in ac-

cordance with column 6 of the § 172.101

table and the following table:

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49 CFR Ch. I (10–1–15 Edition) § 172.400a

Hazard class or division Label name

Label de-sign or sec-

tion ref-erence

1.1 .................................................................................... EXPLOSIVES 1.1 ............................................................ 172.411 1.2 .................................................................................... EXPLOSIVES 1.2 ............................................................ 172.411 1.3 .................................................................................... EXPLOSIVES 1.3 ............................................................ 172.411 1.4 .................................................................................... EXPLOSIVES 1.4 ............................................................ 172.411 1.5 .................................................................................... EXPLOSIVES 1.5 ............................................................ 172.411 1.6 .................................................................................... EXPLOSIVES 1.6 ............................................................ 172.411 2.1 .................................................................................... FLAMMABLE GAS .......................................................... 172.417 2.2 .................................................................................... NONFLAMMABLE GAS .................................................. 172.415 2.3 .................................................................................... POISON GAS .................................................................. 172.416 3 Flammable Liquid (Combustible liquid) ........................ FLAMMABLE LIQUID (none) .......................................... 172.419 4.1 .................................................................................... FLAMMABLE SOLID ....................................................... 172.420 4.2 .................................................................................... SPONTANEOUSLY COMBUSTIBLE .............................. 172.422 4.3 .................................................................................... DANGEROUS WHEN WET ............................................ 172.423 5.1 .................................................................................... OXIDIZER ........................................................................ 172.426 5.2 .................................................................................... ORGANIC PEROXIDE .................................................... 172.427 6.1 (material poisonous by inhalation (see § 171.8 of

this subchapter)).POISON INHALATION HAZARD .................................... 172.429

6.1 (other than material poisonous by inhalation) ........ POISON ........................................................................... 172.430 6.1 (inhalation hazard, Zone A or B) .............................. POISON INHALATION HAZARD .................................... 172.429 6.1 (other than inhalation hazard, Zone A or B) ............. POISON ........................................................................... 172.430 6.2 .................................................................................... INFECTIOUS SUBSTANCE 1 ......................................... 172.432 7 (see § 172.403) ............................................................ RADIOACTIVE WHITE-I ................................................. 172.436 7 ....................................................................................... RADIOACTIVE YELLOW-II ............................................. 172.438 7 ....................................................................................... RADIOACTIVE YELLOW-III ............................................ 172.440 7 (fissile radioactive material; see § 172.402) ................. FISSILE ........................................................................... 172.441 7 (empty packages, see § 173.428 of this subchapter) .. EMPTY ............................................................................ 172.450 8 ....................................................................................... CORROSIVE ................................................................... 172.442 9 ....................................................................................... CLASS 9 .......................................................................... 172.446

1 The ETIOLOGIC AGENT label specified in regulations of the Department of Health and Human Services at 42 CFR 72.3 may apply to packages of infectious substances.

[Amdt. 172–123, 55 FR 52593, Dec. 21, 1990, as amended at 56 FR 66255, Dec. 20, 1991; Amdt. 172–

151, 62 FR 1228, Jan. 8, 1997; 64 FR 10776, Mar. 5, 1999; 64 FR 51918, Sept. 27, 1999; 69 FR 3668,

Jan. 26, 2004; 69 FR 64471, Nov. 4, 2004; 78 FR 60753, Oct. 2, 2013]

§ 172.400a Exceptions from labeling. (a) Notwithstanding the provisions of

§ 172.400, a label is not required on— (1) A Dewar flask meeting the re-

quirements in § 173.320 of this sub-chapter or a cylinder containing a Di-vision 2.1, 2.2, or 2.3 material that is—

(i) Not overpacked; and (ii) Durably and legibly marked in

accordance with CGA C–7, Appendix A (IBR; see § 171.7 of this subchapter).

(2) A package or unit of military ex-plosives (including ammunition) shipped by or on behalf of the DOD when in—

(i) Freight containerload, carload or truckload shipments, if loaded and un-loaded by the shipper or DOD; or

(ii) Unitized or palletized break-bulk shipments by cargo vessel under char-

ter to DOD if at least one required

label is displayed on each unitized or

palletized load. (3) A package containing a hazardous

material other than ammunition that

is—

(i) Loaded and unloaded under the su-

pervision of DOD personnel, and

(ii) Escorted by DOD personnel in a

separate vehicle.

(4) A compressed gas cylinder perma-

nently mounted in or on a transport

vehicle.

(5) A freight container, aircraft unit

load device or portable tank, which—

(i) Is placarded in accordance with

subpart F of this part, or

(ii) Conforms to paragraph (a)(3) or

(b)(3) of § 172.512.

(6) An overpack or unit load device in

or on which labels representative of

each hazardous material in the over-

pack or unit load device are visible.

(7) A package of low specific activity

radioactive material and surface con-

taminated objects, when transported

under § 173.427(a)(6)(vi) of this sub-

chapter.

(b) Certain exceptions to labeling re-

quirements are provided for small


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Pipeline and Haz. Matls. Safety Admin., DOT § 172.402

quantities and limited quantities in ap-plicable sections in part 173 of this sub-chapter.

(c) Notwithstanding the provisions of § 172.402(a), a Division 6.1 subsidiary hazard label is not required on a pack-age containing a Class 8 (corrosive) material which has a subsidiary hazard of Division 6.1 (poisonous) if the tox-icity of the material is based solely on the corrosive destruction of tissue rather than systemic poisoning. In ad-

dition, a Division 4.1 subsidiary hazard

label is not required on a package bear-

ing a Division 4.2 label. (d) A package containing a material

poisonous by inhalation (see § 171.8 of

this subchapter) in a closed transport

vehicle or freight container may be ex-

cepted from the POISON INHALATION

HAZARD or POISON GAS label or

placard, under the conditions set forth

in § 171.23(b)(10) of this subchapter.

[Amdt. 172–123, 55 FR 52594, Dec. 21, 1990]

EDITORIAL NOTE: For FEDERAL REGISTER ci-

tations affecting § 172.400a, see the List of

CFR Sections Affected, which appears in the

Finding Aids section of the printed volume

and at www.fdsys.gov.

§ 172.401 Prohibited labeling. (a) Except as otherwise provided in

this section, no person may offer for

transportation and no carrier may

transport a package bearing a label

specified in this subpart unless: (1) The package contains a material

that is a hazardous material, and (2) The label represents a hazard of

the hazardous material in the package. (b) No person may offer for transpor-

tation and no carrier may transport a

package bearing any marking or label

which by its color, design, or shape

could be confused with or conflict with

a label prescribed by this part. (c) The restrictions in paragraphs (a)

and (b) of this section, do not apply to

packages labeled in conformance with: (1) The UN Recommendations (IBR,

see § 171.7 of this subchapter); (2) The IMDG Code (IBR, see § 171.7 of

this subchapter); (3) The ICAO Technical Instructions

(IBR, see § 171.7 of this subchapter); (4) The TDG Regulations (IBR, see

§ 171.7 of this subchapter). (5) The Globally Harmonized System

of Classification and Labelling of

Chemicals (GHS) (IBR, see § 171.7 of

this subchapter). (d) The provisions of paragraph (a) of

this section do not apply to a pack-

aging bearing a label if that packaging

is: (1) Unused or cleaned and purged of

all residue; (2) Transported in a transport vehicle

or freight container in such a manner

that the packaging is not visible dur-

ing transportation; and (3) Loaded by the shipper and un-

loaded by the shipper or consignee.

[Amdt. 172–9, 41 FR 15996, Apr. 15, 1976, as

amended by Amdt. 172–75, 47 FR 44471, Oct. 7,

1982; Amdt. 172–77, 47 FR 54822, Dec. 6, 1982;

Amdt. 172–94, 49 FR 38134, Sept. 27, 1984;

Amdt. 172–100, 50 FR 41521, Oct. 11, 1985;

Amdt. 172–123, 55 FR 52594, Dec. 21, 1990;

Amdt. 172–132, 58 FR 50501, Sept. 27, 1993; 66

FR 8647, Feb. 1, 2001; 66 FR 45379, Aug. 28,

2001; 68 FR 75741, 75742, Dec. 31, 2003; 74 FR

2252, Jan. 14, 2009]

§ 172.402 Additional labeling require-ments.

(a) Subsidiary hazard labels. Each

package containing a hazardous mate-

rial— (1) Shall be labeled with primary and

subsidiary hazard labels as specified in

column 6 of the § 172.101 table (unless

excepted in paragraph (a)(2) of this sec-

tion); and (2)For other than Class 1 or Class 2

materials (for subsidiary labeling re-

quirements for Class 1 or Class 2 mate-

rials see paragraph (e) or paragraphs (f)

and (g), respectively, of this section), if

not already labeled under paragraph

(a)(1) of this section, shall be labeled

with subsidiary hazard labels in ac-

cordance with the following table:

SUBSIDIARY HAZARD LABELS

Subsidiary hazard level (packing

group)

Subsidiary Hazard (Class or Division)

3 4.1 4.2 4.3 5.1 6.1 8

I ........................... X *** *** X X X X II .......................... X X X X X X X III ......................... * X X X X X X

X—Required for all modes. *—Required for all modes, except for a material with a flash

point at or above 38 °C (100 °F) transported by rail or high-way.

**—Reserved ***—Impossible as subsidiary hazard.

(b) Display of hazard class on labels. The appropriate hazard class or divi-

sion number must be displayed in the


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Appendix J EMS-WI-SW010, Contractor Hazardous Waste Management

Reference Number: EMS-WI-SW010

FORT RUCKER Environmental Management System

Revision Date: 15 SEP 16

Title: Contractor Hazardous Waste Management

Approved By: Misty Howell / Melissa Lowlavar

Page 1 of 6 This is a controlled document.

Verify the latest version online.

1.0 PURPOSE This procedure defines the requirements for managing hazardous waste generated by contractors temporarily working on Fort Rucker. Control of EMS procedures is addressed in procedure EMS-P002, Document Control. 2.0 SCOPE This procedure applies to all contractors that generate hazardous waste who are working temporarily on the installation. Contractors working on the installation long-term as part of regular installation operations (i.e., aviation maintenance contractor, base service support contractor) should refer to management procedures within the Hazardous Waste Management Plan. 3.0 DEFINITIONS

TERM DEFINITION 90-HWAS Less than 90-day Hazardous Waste Accumulation Site Accumulation Start Date (ASD)

The accumulation start date is the date the first item is placed in the container.

Accumulation Threshold

The accumulation threshold is 55-gallons for hazardous waste or 1-quart for acutely hazardous waste.

ADEM Alabama Department of Environmental Management DPW-ENRD Directorate of Public Works, Environmental and Natural

Resources Division, located in Bldg 1121, telephone number 334-255-2541

Hazardous Waste

A solid waste that is not specifically excluded or exempted in ADEM Administrative Code 335-14-2-.01(4)(a)-(b) and that is a listed waste in ADEM Administrative Code 335-14-2 and/or exhibits a characteristic of hazardous waste as defined in ADEM Administrative Code 335-14-2-.03.

HWSAP Hazardous Waste Satellite Accumulation Point is where the hazardous waste is generated and collected in the work place.

Solid Waste Any garbage, refuse, sludge, liquid, semi-solid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural activity. A material is a solid waste after it has been used for its intended purpose, when it is discarded by being abandoned, and sometimes when it is recycled.







4.0 RESPONSIBILITIES

4.1 Contractors. It is the responsibility of each contractor to follow proper procedures for hazardous waste management in accordance with federal and state regulations and this work instruction. Contractors are responsible for paying any fines resulting from noncompliance, which may be as high as $37,500 per violation per day.

4.2 DPW-ENRD Responsibilities. DPW-ENRD will provide additional guidance

as necessary to help ensure compliance with hazardous waste regulations. DPW-ENRD will periodically perform inspections to validate conformance with this procedure. Updates to this procedure will be made by DPW-ENRD as necessary.

5.0 PROCEDURE

5.1 Contractors will identify all wastes that may be generated prior to starting work on the installation. The contractor will work with DPW-ENRD to assess whether any of the wastes that may be generated are hazardous wastes in accordance with ADEM regulations.

5.2 If it is determined that the contractor is expected to generate hazardous

waste, they must coordinate with DPW-ENRD prior to commencement of operations to set up a hazardous waste satellite accumulation point. If a hazardous waste is generated that was not part of the planning process, the contractor must immediately notify DPW-ENRD.

5.3 All contractors must follow federal and state regulations for management of

hazardous waste. This procedure is not a replacement for reading and following the regulations. This procedure and the flowchart in Attachment 2 provide a summary of the requirements for proper management for operations generally conducted on Fort Rucker.

5.4 Waste Accumulation Time.

a. All hazardous waste must be accumulated in a hazardous waste satellite accumulation point (HWSAP) that is at or near the point of generation and that is under the control of the operator. The HWSAP must be secured to prevent unauthorized access. The only waste that should go into the HWSAP container is waste determined by DPW-ENRD to be hazardous waste. If a different type of waste is generated then the contractor must immediately notify DPW-ENRD.







b. Waste may be accumulated in a HWSAP until the container is filled or when the waste exceeds the accumulation threshold (55-gallons for hazardous waste or 1-quart for acutely hazardous waste). When the waste meets the accumulation threshold, the contractor must write the date the container is filled on the container as the accumulation start date.

c. If the accumulation threshold is reached or the container becomes full, the waste must be transferred to a less than 90-day hazardous waste accumulation site (90-HWAS). The contractor will need to have prepared a DD Form 1348-1A to turn in with the waste container at the 90-HWAS. Contact DPW-ENRD for assistance in preparing the DD Form 1348-1A.

d. There are five 90-HWAS. These 90-HWAS are located as follows: 1. Building 1207 on the main post 2. Near Building 1001 on the main post 3. Near the Lowe Army Heliport washrack 4. Near the Hanchey Army Heliport washrack 5. At Cairns Field between Hangars 30103 and 30104 In addition, there is a 180-day HWAS located at Shell Army Heliport that is managed as a 90-HWAS. Waste generated at Cairns and Shell must be turned in to the 90-HWAS and 180-day HWAS located at Cairns and Shell, respectively. At no time will the contractor transport hazardous waste across state roads as this is a violation of federal and state regulations.

5.5 Container Requirements. All hazardous waste must be accumulated in

containers that meet the following requirements: a. The container the waste is accumulated in must be a DOT approved

shipping container. b. The container must be sized appropriately for the amount of waste

to be generated. For example, if it is anticipated that only a gallon of waste will be generated, then use a 5 gallon container for accumulation instead of a 55 gallon drum. Fort Rucker must pay for waste disposal based on the size of the container not the weight. Contact DPW-ENRD for assistance if needed.

c. The container must be compatible with the type of waste being accumulated in the container.

d. DPW-ENRD will provide the contractor with prefilled out labels for the waste containers. Only put waste in the container that has been identified for that HWSAP.

e. Segregate containers of incompatible wastes: 1) Segregate reactive waste from ignitable waste

2) Segregate acids from caustics 3) Segregate corrosive waste from flammable waste







4) Segregate oxidizers from all other wastes f. Containers of highly flammable liquid waste must be grounded. g. Keep containers closed unless actively adding or removing waste. h. Protect containers from direct sunlight and inclement weather. i. Maintain containers in good condition – free of rust, dents, holes, or

other defects that may compromise the integrity of the container. j. Situate containers on a pallet or other device that allows inspection

of all sides of the container. k. All containers of liquid waste must have secondary containment that

is able to hold the entire contents of the container plus 10% freeboard.

5.6 Inspection Requirements.

a. All containers that are in the work place accumulating hazardous waste over 7 days must be visually inspected weekly using USAACE Form 2725, HWSAP Inspection Checklist.

b. Any deficiencies noted during these inspections should be immediately corrected or submitted to supervisor for further action. Contractors should contact DPW-ENRD if they have questions regarding any deficiencies.

c. Personnel conducting the weekly inspections must attend one of Fort Rucker’s HWSAP Manager training classes. The training schedule can be found at the Sustainable Fort Rucker web site under the training tab.

5.8 Training Requirements. a. Federal and state regulations require that all personnel managing or

handling hazardous waste must be trained, either through classroom instruction or on-the-job-training, to respond to emergencies, protect the environment, and properly handle and dispose of hazardous wastes. The regulatory requirements for training may be found in the ADEM Administrative Code 335-14-5-.02(7).

b. Facility personnel whose duties have a direct effect on hazardous waste management and/or hazardous waste accumulation, whether by direct contact with the hazardous waste or through hazardous waste management activities, must receive training. Each person managing or handling hazardous waste must receive introductory and annual update hazardous waste training corresponding with his/her responsibilities. The annual update training must be completed within 365 days of the previous training.

c. The introductory training must be completed within six months of the date on which the employee begins work in a position requiring such training. Employees must be immediately and continuously







supervised when performing hazardous waste duties until such training is completed.

d. At a minimum, all supervisors and managers of hazardous waste activities will take a training course that meets required standards. It is their responsibility to ensure that personnel working for them are trained either in formal courses or in-house using on-the-job-training and "shop level" classes to meet the regulatory requirements.

e. Training records must be maintained for three years after the personnel cease working for the contractor.

5.9 Spill Prevention and Response

a. Site Specific Spill Plan. Each organization using hazardous materials and generating hazardous waste must complete USAACE Form 2719, Site Specific Spill Plan, which is available on the Sustainable Fort Rucker website. It is also referenced in the Installation Spill Contingency Plan (ISCP). The organization must have a hard copy readily available at each location that stores hazardous material and/or hazardous waste.

b. Spill Response. In the event that hazardous material or hazardous waste spills or leaks, the contractor must notify the Fire Department (call 911). The contractor is responsible for ensuring it is properly cleaned up in accordance with guidance from the Fire Department and DPW-ENRD.

c. Spill residue that contains a hazardous material or hazardous waste should be managed in accordance with the requirements in Sections 5.3 and 5.4. If the waste is waiting for laboratory analysis, the container should be marked PENDING ANALYSIS, dated with the date the sample was taken and turned into the 90-HWAS.

d. Spill residue that is or may potentially be a hazardous waste must not be removed from the installation without a manifest signed by authorized personnel within DPW-ENRD.

6.0 REFERENCES AND FORMS Sustainable Fort Rucker website: http://www.fortrucker-env.com EMS-P002, Document Control Hazardous Waste Management Plan (HWMP) Installation Spill Contingency Plan (ISCP) EPA Form 8700-22, Uniform Hazardous Waste Manifest USAACE Form 2719, Site Specific Spill Plan USAACE Form 2725, HWSAP Inspection Checklist USAACE Form 2726, 90-HWAS Inspection Log DD Form 1348-1A

ATTACHMENT 1



Contractor Hazardous Waste Procedures

Accumulate hazardous waste in DOT approved,

compatible container

Contact DPW-ENRD (334-255-1024) prior to starting work to obtain assistance with identifying waste and setting up HWSAP

Label container with pre-filled labels obtained

from DPW-ENRDstating “HAZARDOUS

WASTE” and contents of container

Store properly

Transfer waste to 90-HWAS when

accumulation threshold reached

Inspect weekly using USAACE

Form 2725

Segregate incompatible wastes

Ground highly flammable wastes

Keep elevated off floor (i.e., on a pallet)

Keep containers closed unless adding or removing waste

Protect from direct sunlight & inclement weather

Provide adequate secondary containment for containers of

liquid waste

“ACCUMULATION START DATE:______“ indicating date container was filled

Prepare DD Form 1348-A1 for turn in to 90-HWAS. Contact DPW-

ENRD for assistance.

Complete manifest with all required information

HWSAP accumulation threshold: 55-gal HW or 1-qt acute HW

Store hazardous waste in HWSAP in accordance with Federal & State Regulations

Segregate reactive HW from ignitable HW

Segregate acids from caustics

Segregate corrosive HW from flammable HW

Segregate oxidizers from all other wastes

No leaks, dents, corrosion, bulging, or noticeable spills

Overpack any leaking containers

Immediately clean up any spills

Contact DPW-ENRD to arrange for signing manifest

Complete HW label and place on container

Mark container with appropriate hazard markings (49 CFR

172.400)

Proper DOT Shipping Name

Fort Rucker (Contractor name), building number, &

phone number

Fort Rucker EPA ID # Main Post AL6 210 020 776

Cairns AL9 210 090 040Shell AL2 210 090 039

Applicable Waste Codes

The statement, “FEDERAL LAW PROHIBITS IMPROPER

DISPOSAL. IF FOUND, CONTACT THE NEAREST

POLICE OR PUBLIC SAFETY AUTHORITY OR THE US

ENVIRONMENTAL PROTECTION AGENCY.”

Waste must be removed within 3 days of reaching accumulation

thresholdMaintain containers in good

condition

Appendix K EMS-WI-SW001, Waste Turn-In Procedure




Title: Waste Turn-In Procedure




1.0 PURPOSE This procedure defines the requirements for turning in solid wastes for management by Defense Logistics Agency Disposition Service (DLADS). Control of EMS procedures is addressed in procedure EMS-P002, Document Control. 2.0 SCOPE This procedure applies to all operations involving solid waste with hazardous constituents, including all activities and tenants that generate, recycle or reclaim waste, including those activities located at facilities outside the contiguous boundary of Fort Rucker. The requirements of this procedure are applicable to all military, civilian and contract personnel at Fort Rucker. 3.0 DEFINITIONS

TERM DEFINITION DLADS Defense Logistics Agency Disposition Service DPW-ENRD Directorate of Public Works, Environmental and Natural Resources

Division, located in Bldg 1121, telephone number 334-255-1024. HMCC Hazardous Material Control Center, located in Bldg 1315, telephone

number 334-598-1311. 90-HWAS Less Than 90-Day Hazardous Waste Accumulation Sites (also applies

to the less than 180-Day site located at Shell) HWMP The Fort Rucker Hazardous Waste Management Plan documents

personnel and procedures to ensure each step in the "cradle-to-grave" management of hazardous wastes is carried out in a consistent manner and in accordance with regulatory requirements. Procedures are either referenced or included in this HWMP, as necessary, to provide documented hazardous waste management instructions, from the time of waste generation until it is transported offsite for reuse or disposal.

4.0 RESPONSIBILITIES It is the responsibility of each waste generator to follow these procedures.







5.0 PROCEDURE 5.1 Turn-In Document

5.1.1 A DD Form 1348-1A is to be completed for all containers turned in

for waste disposal, recycle or reclamation. 5.1.2 The DD Form 1348-1A may be obtained from DPW-ENRD or the

HWMP. 5.1.3 Use the following instructions to complete the DD Form 1348-1A.

Using the areas marked on the example of DD Form 1348-1A below, fill in the numbered areas with the following information: Item 1. Box #2 “Ship From”: Type the name of the generator, or the name of the agency who created the waste, and “Ft. Rucker”. Item 2. “Units Issued”: To designate if the containers are drums or boxes, type “DR” for drums or “BX” for box. Item 3. “Qty”: Type the number of containers being shipped with this document. i.e. Type “2” for two drums of waste to be shipped. (One TYPE of waste per document.) Item 4. “Fund”: Type the number provided to your agency by the Hazardous Waste Program Manager. Item 5. “Dollars CTS”: Type the cost per container from the correct waste profile. NOTE: Item 5 is located at the top of the form and at the bottom. Enter the cost in both locations. Please reference the most recent waste profile list provided by the Hazardous Waste Program Manager. Item 6. Box 4 “Mark For”: Type “NON-RCRA” for Non-RCRA waste, “HAZARDOUS WASTE” for hazardous waste, or “UNIVERSAL WASTE” for universal waste as designated on the applicable waste profile. Please reference the most recent waste profile list provided by the Hazardous Waste Program Manager. Item 7. “Document Number and Suffix”: Unless your organization has a different code (check with Hazardous Waste Program Manager) type “W31BMV” then enter the 4-digit Julian Date followed by the number “1525”. With each additional DD Form 1348-1A created in a single day, add 1 to the number “1525”. i.e. The first document of







the day is “W31BMV-6230-1525”, the second document is “W31BMV-6230-1526”, and so on.

Item 8. “DOT Shipping Name”: Copy the DOT Shipping name exactly as it appears on the waste profile list. Please reference the most recent waste profile list provided by the Hazardous Waste Program Manager. Item 9. “National Stock Number (NSN)”: Copy the National Stock Number exactly as it appears on the waste profile list. Please reference the most recent waste profile list provided by the Hazardous Waste Program Manager. Item 10. “Bill To”: Type the number provided to your agency by the Hazardous Waste Program Manager. Item 11 a. “Item”: Copy the waste name exactly as it appears on the waste profile list. Please reference the most recent waste profile list provided by the Hazardous Waste Program Manager. Item 11b. “Waste Codes”: If the waste is a Hazardous Waste, then copy the waste codes exactly as it appears on the waste profile list. If the waste Universal Waste or Non-RCRA Waste, enter “n/a”. Please reference the most recent waste profile list provided by the Hazardous Waste Program Manager. Item 12. “TY CONT”: Use the following list to enter the correct container type and size code for the waste.

DM (drum, metal) + capacity (5, 40, 55 gal) DF (drum, fiber or plastic) CF (carton, fiber) = box CW (crate, wooden) = pallet Item 13. “Total Weight”: If your agency has a properly calibrated and maintained scale, then please enter the weight of the waste container. However, this item is optional and the container will be weighed at turn-in even if a weight has been entered in this space. Item 14. “CLIN”: Copy the CLIN exactly as it appears on the waste profile list. Please reference the most recent waste profile list provided by the Hazardous Waste Program Manager.







Item 15. “Profile Number”: Copy the profile number exactly as it appears on the waste profile list. Please reference the most recent waste profile list provided by the Hazardous Waste Program Manager. Item 16. “EPA ID”: Enter the EPA ID code, as listed at the top of the Waste Profile List, for the area where the waste was produced. i.e. If the waste was produced within the Main Cantonment Area, Enter “AL6210020776.” Item 17. “Certified By”: Leave blank. To be signed at turn-in by the person accepting the waste at the HMCC.

Additional Information: The “POC” listed on the lower right-hand side of the form is the name of the person who created the document. This person must also sign the “Inspected By” line at the bottom right-hand of the form. You may NOT create DD Form 1348-1A documents for waste turn-in unless you have completed the proper training. DPW-ENRD provides the required training classes each quarter. See http://fortrucker-env.com to register for classes.







5.2 Activities Located within the Boundary of Fort Rucker For activities located within the physical boundary of Fort Rucker generating waste with hazardous constituents, the following applies:

5.2.1 Turn-in of waste containers will occur Thursday morning between

0900 and 1130 at Bldg 1207, or may be scheduled for other days/times by appointment if necessary. The original and two copies of the completed DD Form 1348-1A are to accompany waste containers being generated for turn-in at the 90-Day Hazardous Waste Building 1207. Note that the generator of the waste is responsible for completing the form correctly and obtaining required/authorized signatures. 5.2.1.1 One copy of the DD Form 1348-1A will be signed by the

HMCC Waste Manager/Representative and returned to the customer.

5.2.1.2 One copy of the DD Form 1348-1A will be attached to the respective container. If more than one container of the same type is noted, the form will be attached to the one with the oldest accumulation start date, with the document number being written on all applicable containers.

5.2.2 HMCC will provide original DD Forms 1348-1A from each week’s turn-ins to DPW-ENRD prior to noon on Friday for each week.

5.3 Activities Located Outside the Boundary of Fort Rucker

For activities located outside the physical boundary of Fort Rucker generating waste with hazardous constituents, the following applies:

5.3.1 One copy of the completed DD Form 1348-1A will be provided to the

DPW-ENRD within one week of waste turn-in. Note that the generator of the waste is responsible for completing the form correctly and obtaining required/authorized signatures.

5.3.2 One copy of the DD Form 1348-1A is to be attached to the respective container. If more than one container of the same type is noted, the form will be attached to the one with the oldest accumulation start date, with the document number being written on all applicable containers.

5.4 HMCC Responsibilities

5.4.1 The Hazardous Waste Manager will ensure containers are not damaged prior to accepting into the 90-HWAS at Building 1207. Waste that is not properly labeled and identified or that is not properly







packaged and safe to handle will not be accepted. Containers that are found to be leaking, corroded, or otherwise deteriorated must be either transferred to a different container or over packed in a DOT-approved container prior to accepting.

5.4.2 Each DD Form 1348-1A will be reviewed for completeness and accuracy prior to receiving the waste into the 90-Day HWAS at Bldg 1207. Items found to be incorrect or incomplete are to be corrected by the generator prior to receiving the waste.

5.4.3 The HMCC will provide original documents to DPW-ENRD by noon each Friday. Should a holiday fall on Friday, all data will be turned in the next available work day.

5.5 DPW-ENRD Responsibilities DPW-ENRD will review DD Forms 1348-1A for accuracy and ensure waste information is transferred to DLADS for Delivery Orders as required.

6.0 FORMS AND RECORDS DD Form 1348-1A 7.0 REFERENCES EMS-P002, Document Control Hazardous Waste Management Plan

Appendix L Hazardous Waste Profile

_

(If Yes, Enter Reference Standards in Part 3, Block 6)

Oct 2006

DRMS FORM 1930, Oct 2006 (EF)

INSTRUCTIONS FOR DRMS FORM 1930 (Authority: DOD 4160.21-M, Chap. 10, par. D.2.a.(3))

PART I A. GENERAL INFORMATION (Required) WASTE PROFILE NUMBER – A unique number assigned to this waste stream for future reference. The preferred format is Generator DoDAAC + five digit serial number assigned by either the Generator or the DRMO. Any variation from this format must be approved by your DRMO. 1. GENERATOR NAME – Enter the name of the generating facility. (Should match official name associated with the EPA ID number). 2. FACILITY ADDRESS – Enter the address of generating facility listed in block A.1. 3. ZIP CODE – Enter the generating facility’s five or nine-digit Zip Code. 4. GENERATOR USEPA ID – Enter the 12-character, alpha-numeric descriptor issued by the USEPA to the facility identified in block A.1. (If not applicable, enter “NONE”) 5. GENERATOR STATE ID – Enter the descriptor issued by the Resident State to the facility identified in block A.1. 6. TECHNICAL CONTACT – Enter the name of the person to contact for more information about this waste. 7. TITLE – Enter the Technical Contact’s official title (e.g., “HW-Manager”, “Shop Chief”, etc.). 8. PHONE – Enter the Technical Contact’s telephone number B. WASTE INFORMATION (Required) 1. NAME OF WASTE – Enter a name that is generally descriptive of this waste (e.g., paint wastes, oil-water separator sludge, PCB-contaminated dirt, etc.) 2A. USEPA WASTE CODE(S) – List all that apply. If non-RCRA, enter “NONE” 2B. STATE/LOCAL/HOST NATION WASTE CODE(S) – List all that apply. If not applicable, enter “NONE”. 3. PROCESS GENERATING WASTE – List the specific process/operation or source that generates this waste (e.g., paint-booth spray, PCB spill, metal-plating operation, etc.) 4. PROJECTED ANNUAL GENERATIONS – The quantity of waste projected for turn-in annually. (preferably in pounds, but other units of measure may be used, e.g., gallons, kilograms, etc.) 5. MODE OF COLLECTION – Describe the method used to collect and store this waste stream (e.g., drums, tanks, roll-off, etc.) 6. DIOXIN WASTE? – Storage and disposal of Dioxin wastes requires special attention. If this waste is a USEPA-listed Dioxin waste, indicate “Yes”, and contact your DRMO representative for further instructions. 7. A. IS THIS WASTE RESTRICTED FROM LAND DISPOSAL? – Check “YES” or “NO” B. HAS AN EXEMPTION BEEN GRANTED? – If “Yes”, explain in Part II, block 6, at “Explain how and why these documents comply with RCRA requirements”. C. DOES THE WASTE MEET APPLICABLE TREATMENT STANDARDS ALREADY? If “Yes”, explain in Part II, block 6, at “Explain how and why these documents comply with RCRA requirements”.

PART II 1. MATERIAL CHARACTERIZATION (Optional unless otherwise indicated) 1. COLOR – Describe the color of the waste (e.g., blue, clear, varies, etc.) 2. DENSITY – The specific gravity of water is 1.0. Most organics are less than 1.0. Chlorinated solvents, most inorganics, and paint sludge are greater than 1.0. 3. BTU/LB – This entry may be required if you request that this waste be used as a fuel substitute. 4. ASH CONTENT – This entry may be required is you request recovery of used oil. 5. TOTAL SOLIDS – Content can be expressed as either a weight percentage, or dry-weight concentration (mg/kg). 6. LAYERING – Check applicable box. Multi-layered means more than two layers (e.g., oil/water/solvent/sludge). Bilayered means the waste is comprised of two layers which may or may not be the same phase (e.g., oil/water, solvent/sludge). Single phase means the waste is homogeneous. 2. RCRA CHARACTERISTICS (Required as applicable) PHYSICAL STATE – If the four boxes do not apply, a description should be entered after “Other”. IGNITABLE – Check this box if the waste meets the criteria listed at 40 CFR 261.21. FLASH POINT – For liquids, list the flash point, regardless of whether the waste is Ignitable(D001) or NOT. TOTAL ORGANIC CARBON (TOC) – Required for Ignitable Liquids CORROSIVE – Check this box if the waste is corrosive as defined in 40 CFR 261.22. - If applicable, include the PH reading in the space provided. (40 CFR 261.22 (a)(1). - If applicable, check the “Corrodes Steel” box. (40 CFR 261.22 (a)(2). REACTIVE – Indicate if the waste is reactive as defined in 40 CFR 261.23. If so, indicate the reason by checking the appropriate box. If other than one of the reasons provided, explain in detail at Part II, “Special Handling Requirements”. TOXICITY CHARACTERISTIC – If the waste exhibits the characteristic of toxicity, as defined in 40 CFR 261.24, check this box, and include the contaminant level in Part II, block 3.

3. CHEMICAL/MATERIAL COMPOSITION (Required as applicable) CAS # - Chemical Abstract Number. (Optional) May be used instead of the chemical name in the “Component” block. COMPONENT – List all chemical and material components and contaminants. - Examples of chemical components and contaminants:

• “PCB’s”, “ methanol”, “oil”, “endrin”, “sodium chloride”, “napthalene”, “gasoline”, etc. • applicable F-listed constituents; e.g., for waste numbers F001-F005, the waste constituents of concern are

the solvents themselves. • applicable Underlying Hazardous Constituents (UHCs). For certain characteristic waste numbers, D001-

D043, you may have to examine the waste components for UHCs. Look in 40 CFR, Table 268.40. If the treatment standard given includes the words “and meet 268.48 standards”, then you must indicate any UHCs present in the waste if they are present above the levels specified in part 268.48.

- Examples of material components and contaminants: water, dirt, sand, paint sludge, rags, etc. CONCENTRATION – Use this column for constituents of concern which do not exceed 10,000 ppm (1%). Indicate the concentration level in ppm or mg/L. RANGE – For components comprising greater than or equal to 1% of the total waste stream, estimate the range (in percent) in which the component is present. The total maximum values of the components must be greater than, or equal to 100%, including chemical and material components. 4. SHIPPING INFORMATION - Refer to 49 CFR 172 to complete this part. NOTE: Information provided in this portion of the waste profile is not meant to constitute a standard USDOT certificate given by a shipper offering a package to a transporter, but is needed to identify any other health and safety hazards, which are not readily apparent from the basic waste description. 5. SPECIAL HANDLING INFORMATION - Describe those hazards which you know or reasonably believe are or may be associated with short term or prolonged human exposure to this waste (29 CFR 1910.1200). If known, please identify any carcinogens present in this waste in excess of 0.1% (29 CFR 1910.1200(d)(4). Failure to make an entry in this part is considered to be a representation that you neither know nor believe that there are any adverse human health effects associated with exposure to this waste. Also include any additional information that will aid in the management of this waste. 6. GENERATOR CERTIFICATION (Required) CHEMICAL ANALYSIS – Attach a copy, if applicable (see Note below). USER KNOWLEDGE - User knowledge is appropriate when it can be documented (e.g., in-out logs, published information, MSDS, process production information, etc.). There is room provided to explain “what’ and “why” user knowledge is used in lieu of analysis. CERTIFICATION - Include the PRINTED NAME of the person providing the Certification Signature. SIGNATURE - An authorized representative of the generator must sign and date this certification on the completed Hazardous Waste Profile Sheet. DATE – Date signed by Certifier*. * This Hazardous Waste Profile Sheet (HWPS) may be used for subsequent turn-ins of the same waste stream, for a period of one year. If a turn-in date is more than a year past the Certification Date listed, the generator must either re-certify the HWPS, or provide a new HWPS, with the current date. See instructions at DOD 4160.21-M, Chapter 10, par. D.2.a.(3)(b).

If you require assistance completing this form, please contact your local DRMO

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Appendix M Container Labels

Appendix N USAACE Form 2730, Hazardous Material Authorization Request

HAZARDOUS MATERIAL AUTHORIZATION REQUESTFor use of this form, see Hazardous Waste Management Plan; the proponent is DPW-ENRD

Employee Name Phone

Requesting Organization

Organization DoDAAC

National Stock Number Nomenclature

Part Number Military Specification

Container Size Preferred Container Type

One-Time Need Stocked Permanently

Location(s) where product will be used/ Work Zone

Date:Approved

YES NO

Site Supply Supervisor

Site EH&S Coodinator

DPW-ENRD

HMCC Manager

Justification (TM, Manufacturer’s Specification, etc):

Printed Name and ID number (if applicable)

I. Requestor Information

(Responsible Supervisor Name, ID, Organization, Telephone)

II. Responsible PartiesI CERTIFY THAT THE MATERIAL IS REQUIRED AS STATED ABOVE

Approving Activity Date Signature/Comments

Signature:

Special conditions for using chemical (if any):

Organization and Telephone:

Description of Product Use/Process (describe work activity by which material will be used. Identify method of application):

Frequency of UseUnit of Measure

USAACE FORM 2730 (rev 15JUN16)THIS IS A CONTROLLED DOCUMENT.

VERIFY THE LATEST VERSION ONLINE.

Appendix O EMS-WI-SW009, Absorbent Continued Use Program




Title: Absorbent Continued Use Program




1.0 PURPOSE This procedure defines the requirements for managing absorbent pads, socks, wipes, mop heads, pillows and gloves for continued use. Control of EMS procedures is addressed in procedure EMS-P002, Document Control. 2.0 SCOPE This procedure applies to all operations involved in managing absorbent materials for continued use. This procedure applies to all military, civilian and contract personnel that order, supply, process, store, use, and track absorbents for continued use on Fort Rucker. 3.0 DEFINITIONS

TERM DEFINITION Absorbent Materials Pads, socks, wipes, pillows, gloves, and mopheads AUL Authorized Use List DPW-ENRD Directorate of Public Works, Environmental and Natural

Resources Division, located in Bldg 1121, telephone number 334-255-2541

HMCC Hazardous Material Control Center, located in Bldg 1315, telephone number 334-598-1311

QVL Qualified Vendor List 4.0 RESPONSIBILITIES

4.1 DPW-ENRD 4.1.1 Ensure installation-wide adherence to established policies and

procedures for the absorbent continued use program. 4.1.2 Maintain tracking documents (USAACE Form 2732).

4.2 Absorbent Supplier / Processor

4.2.1 Ensure appropriate pick-up and delivery service to the absorbent users.

4.2.2 Process and transport contaminated or used absorbents in accordance with regulatory requirements.

4.2.3 Provide documentation as required by the absorbent continued use procedure.







4.2.4 Provide certification documentation as required by an ADEM approved absorbent continued use process.

4.2.5 Handle absorbent materials as a valuable commodity.

4.3 HMCC 4.3.1 Receive absorbent requests from the absorbent user and place the

order with the absorbent supplier/processor. 4.3.2 Ensure absorbent supplier/processors are on the Qualified Vendor

List (QVL).

4.4 Absorbent User 4.4.1 Adhere to established policies and procedures for the absorbent

continued use program, including segregation of used products, weighing of used materials, etc.

4.4.2 Handle absorbent materials as a valuable commodity. 4.4.3 Provide tracking data on used absorbents using USAACE Form

2732, Continued Use Absorbents Tracking Document.

5.0 PROCEDURE

5.1 Order absorbent materials 5.1.1 The absorbent user requests on their approved AUL the quantity

and type of absorbent needed by the date specified by the supplier. Specific items available for order are included in the pick lists on USAACE Form 2732, Continued Use Absorbents Tracking Document.

5.1.2 HMCC places the absorbent order with the supplier/processor.

5.2 Deliver absorbent materials 5.2.1 Supplier/processor delivers the absorbent user’s order to pre-

designated delivery points. 5.2.2 Supplier/processor provides user with a copy of the delivery

document to include but not limited to the delivery date, delivery location, container contents, container weight and drum identification number.

5.3 Use of absorbent materials

5.3.1 All used absorbent materials must be handled in a responsible manner (i.e. they must be handled as a valuable commodity).

5.3.2 Used absorbent materials must be segregated and placed into the drums provided by the supplier/processor for return. User will ensure that all trash and other debris is kept out of the drums.







5.3.3 All materials that are considered unserviceable after being returned from the supplier/processor must be managed as a waste.

5.4 Pick-up of absorbent materials

5.4.1 User will stage drums containing used absorbent materials for return at pre-designated pick-up points.

5.4.2 User will provide DPW-ENRD with drum identification numbers, deliver/pickup date, total weight and number of drums returned, using USAACE Form 2732, Continued Use Absorbents Tracking Document. This information should be provided to DPW-ENRD in a timely manner after the transaction has been completed.

5.5 DPW-ENRD will maintain tracking information for absorbent materials 5.6 Processing of absorbent materials at supplier facility

5.6.1 All used absorbent materials must be handled in a responsible manner (i.e. they must be handled as a valuable commodity).

5.6.2 All used absorbent materials must be processed for continued use in accordance with regulatory requirements.

5.6.3 All materials that are clearly unserviceable after use must be managed as a waste.

5.6.4 All items that are sent to the supplier/processor must be returned to Fort Rucker even if they are remnants.

5.6.5 The supplier/processor must ensure that absorbent materials are cleaned, segregated, and returned to the central activity of origination (i.e. absorbent materials coming from the Facilities Maintenance Contractor will be returned to Facilities Maintenance Contractor, absorbent materials from Aircraft Maintenance Contractor will be returned to Aircraft Maintenance Contractor, etc.).

6.0 FORMS AND RECORDS USAACE Form 2732, Continued Use Absorbents Tracking Document 7.0 REFERENCES EMS-P002, Document Control

Appendix P USAACE Form 2732, Continued Use Absorbents Tracking Document

CONTINUED USE ABSORBENTS TRACKING DOCUMENTFor use of this form, see EMS-WI-SW009; the proponent is DPW-ENRD

LocationOrganizationPOC

DRUM NUMBER

WEIGHT (LBS)

DRUM NUMBER

WEIGHT (LBS)

0 0 0 0

TOTAL

Comments

TURNED INRECEIVED OR TURNED

IN?

RECEIVEDABSORBENT TYPE DATE NOTES

USAACE FORM 2732 (rev 15JUN16)THIS IS A CONTROLLED DOCUMENT.

VERIFY THE LATEST VERSION ONLINE.

Appendix Q EMS-WI-SW002, Used Battery Management




Title: Used Battery Management




1.0 PURPOSE This procedure defines the requirements for management of used batteries on Fort Rucker. Control of EMS procedures is addressed in procedure EMS-P002, Document Control. 2.0 SCOPE This procedure applies to all operations that generate, transport, and temporarily store used batteries prior to turn-in for recycling, including those activities located at facilities outside the contiguous boundary of Fort Rucker. The requirements of this procedure are applicable to all military, civilian and contract personnel at Fort Rucker. 3.0 DEFINITIONS/REFERENCES

TERM DEFINITION 90-HWAS Less Than 90-Day Hazardous Waste Accumulation Site Accumulation Start Date (ASD)


DOT Department of Transportation DPW-ENRD Directorate of Public Works, Environmental and Natural Resources

Division, located in Bldg 1121, telephone number 334-255-1024. HMCC Hazardous Material Control Center, located in Building 1315,

telephone number 334-598-1311. HWMP The Fort Rucker Hazardous Waste Management Plan documents

personnel and procedures to ensure each step in the "cradle-to-grave" management of wastes with hazardous characteristics is carried out in a consistent manner and in accordance with (IAW) regulatory requirements. Procedures are either referenced or included in this HWMP, as necessary, to provide documented hazardous waste management instructions, from the time of waste generation until it is transported offsite for reuse or disposal.

HWSAP Hazardous Waste Satellite Accumulation Point IAW In Accordance With Universal Waste

Universal wastes are hazardous wastes that are subject to less stringent hazardous waste management regulations, particularly by allowing more time for accumulation of these wastes in order to facilitate appropriate recycling or disposal. Four types of waste are







TERM DEFINITION covered under the universal waste regulations: batteries, lamps, mercury-containing equipment, and pesticides.

Used Battery

A device that produced electricity and may have several primary or secondary cells arranged in parallel or series. The typical batteries that are used at Fort Rucker are:

Alkaline and Carbon-Zinc (e.g., 9-volt, D, C, AA, AAA, alkaline button) – Managed as Non-Hazardous Waste

Lithium, Nickel-Cadmium (NiCd), Mercuric-Oxide (button and other), Nickel-Metal Hydride (NiMH), Silver Oxide, Silver-Zinc, Zinc-Carbon, Zinc Air – Managed as Universal Waste

Lead-acid – Managed as one-for-one exchange for recycling. 4.0 RESPONSIBILITIES It is the responsibility of each unit, organization or contractor working on Fort Rucker to follow these procedures. 5.0 PROCEDURE 5.1 Non-Hazardous Used Batteries

5.1.1 Used single-use dry cell Alkaline and Carbon-Zinc batteries (e.g., 9-volt, D, C, AA, AAA, alkaline button) will be managed as Non-Hazardous Waste.

5.1.2 Non-Hazardous used single-use dry cell Alkaline and Carbon-Zinc batteries (e.g., nine-volt, D, C, AA, AAA, alkaline button) batteries will be collected and segregated from Universal Waste batteries (e.g., Lithium, Mercury, NiCd) and Lead-Acid batteries in separate containers.

5.1.3 Accumulating Used Non-Hazardous Batteries: 5.1.3.1 Each unit, organization or contractor must collect the used single-

use dry cell Alkaline and Carbon-Zinc batteries in a DOT approved container with a closing lid.

5.1.3.2 The individual, spent, dry cell Alkaline and Carbon-Zinc batteries are not required to be separated. They may simply be containerized in a DOT approved container. See U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration clarification letter dated 23 Jun 2009 for additional information regarding this Non-Hazardous/Non-Regulated Waste.

5.1.3.3 The unit, organization or contractor will ensure each container has the proper label affixed. The label must identify the specific type of battery to be accumulated in the container (e.g., Non-Hazardous Waste Used Alkaline Batteries). The label must meet the following requirements:







-all labels must be visible on the container; and -all labels must contain:

the words "Non-Hazardous Waste", and the words “Used Alkaline/Carbon Zinc Batteries”, and the accumulation start date (ASD) (the date the first used

battery was placed in the container). 5.1.4 The unit, organization or contractor is to coordinate the turn-in of the used

batteries with the HMCC Customer Service Representative at 598-1311. 5.1.5 HMCC personnel will remove the lid of each container before accepting

batteries to ensure co-mingling of battery types has not occurred. Used batteries that have not been properly segregated or properly packaged will not be taken.

5.1.6 All containers holding used batteries are to be maintained, closed (as defined by the container manufacturer), labeled, and in good condition. Spill equipment is to be near the used battery accumulation site. Management of these used battery accumulation areas is to be IAW the Installation's HWMP at all times.

5.2 Universal Waste Batteries

5.2.1 Used Lithium, NiCd, Mercuric-Oxide (button and other), NiMH, Silver Oxide, Silver-Zinc, Zinc-Carbon, and Zinc Air batteries will be managed as Universal Waste.

5.2.2 Accumulating Universal Waste Batteries: 5.2.2.1 Universal Waste batteries (e.g., Lithium, NiCd, Mercuric-Oxide,

NiMH, Silver Oxide, Silver-Zinc, Zinc-Carbon, and Zinc Air) will be collected and segregated in separate DOT approved containers with a closing lid.

5.2.2.2 Units, organizations or contractors are responsible for ensuring that all used batteries are properly separated by Universal Waste Battery types to prevent short-circuiting during storage and transportation. Universal Waste batteries will be separated by one of the following methods:

-placing batteries in the original inner package; -taping the positive end of the batteries; or, -by using plastic “baggies” to separate individual batteries. 5.2.2.3 The unit, organization or contractor will ensure each container has

the proper label affixed. The label must identify the specific type of battery to be accumulated in the container (e.g., Universal Waste for Lithium, Mercury, NiCd). The label must meet the following requirements:

-all labels must be visible on the container; and, -all labels must contain:

the words "UNIVERSAL WASTE", and







the words describing the type of battery (e.g., “Lithium Batteries”, and

the accumulation start date (ASD) (the date the first used battery was placed in the container).

5.2.2.4 All containers holding used batteries are to be maintained, kept closed (as defined by the container manufacturer), labeled, and in good condition. Spill equipment is to be near the used battery accumulation site. Management of these used battery accumulation areas is to be IAW the Installation's HWMP at all times.

5.2.3 Turning In Universal Waste Batteries: 5.2.3.1 Universal Waste batteries must be turned in for disposal within six

months of the ASD, regardless if full or not. Containers of Universal Waste batteries for turn in are to be accompanied by a completed DD Form 1348-1A.

5.2.3.2 The unit, organization or contractor is to coordinate the turn-in of Universal Waste batteries with the HMCC Customer Service Representative at 598-1311.

5.2.4 HMCC personnel will remove the lid of each container before accepting batteries to ensure co-mingling of battery types has not occurred. Used batteries that have not been properly segregated or properly packaged will not be taken.

5.2.5 The HMCC will not accept batteries that have not been segregated or properly packaged to prevent short-circuiting.

5.3 Lead-Acid Batteries

5.3.1 Units, organizations or contractors will recycle used lead-acid batteries using the one-for-one exchange program. This program provides a one-for-one exchange of new lead-acid batteries for unserviceable lead-acid batteries.

5.3.2 Accumulating Lead-Acid Batteries for Recycling: 5.3.2.1 Both new and used lead-acid batteries should be stored in

covered areas on pallets or in a covered spill containment pallet. 5.3.2.2 Lead-acid batteries do not need to be labeled. 5.3.2.3 Draining batteries before collection is not necessary. 5.3.2.4 Although lead-acid batteries are not managed as Universal

Waste, the unit, organization or contractor should not accumulate the batteries for an extended period of time and should implement a method to demonstrate how long the lead-acid batteries have been stored between shipments.







5.3.3 Recycling Used Lead-Acid Batteries: 5.3.3.1 Units, organizations or contractors are responsible for ensuring

that used lead-acid batteries are properly recycled using the one-for-one exchange program.

5.3.3.2 The one-for-one exchange program vendor supplies new batteries to organizations and picks up any used batteries that have been collected.

5.3.3.3 The vendor takes the entire lead-acid battery (including the electrolyte solution) and transports the batteries to a battery recycler for recycling.

5.3.3.4 If the vendor does not have a particular facility on their pickup route, the unit, organization or contractor may turn in their used lead-acid batteries to the HMCC.

5.3.3.5 The unit, organization or contractor is to coordinate the turn-in of used lead-acid batteries with the HMCC Customer Service Representative at 598-1311.

5.3.4 A battery acid spill kit is to be near the used lead-acid battery accumulation site. Management of these used battery accumulation areas is to be IAW the Installation's HWMP at all times.

5.4 Leaking or Damaged Batteries

5.4.1 Leaking or damaged Non-Hazardous and Universal Waste batteries will be segregated from intact used batteries by placing the leaking or damaged battery in a sealed plastic bag or wrapped with plastic and sealed using tape. Once sealed, the leaking or damaged battery may be placed in the appropriate collection container.

5.4.2 Lead-acid batteries that are leaking or are damaged (e.g., cracked case) cannot be returned to the vendor as part of the one-for-one exchange program. These batteries will be accumulated in a HWSAP and turned in to the 90-HWAS for disposal as hazardous waste.

5.4.3 Units, organizations and contractors will have spill equipment and training to safely and efficiently clean up minor spills and releases of battery electrolyte solutions IAW the Installation Spill Contingency Plan.

5.4.4 Personnel should collect the clean-up wastes in an approved non-metal container or a metal container with an appropriate liner. Wastes from the clean-up of electrolyte solution will be managed and disposed of as hazardous waste IAW the HWMP.

6.0 FORMS AND RECORDS DD Form 1348-1A Inspection Records







7.0 REFERENCES EMS-P002, Document Control 49 CFR Parts 171-180 US DOT Battery Clarification Letters Dated April 3, 2009, June 23, 2009, and November 25, 2009 DOD 4160.21-M, Chapters 4 and 10 Hazardous Waste Management Plan Installation Spill Contingency Plan

Appendix R EMS-WI-SW007, Management of Used Oil and Fuel Filters




Title: Management of Used Oil and Fuel Filters




1.0 PURPOSE This procedure defines the requirements for managing used oil filters and used fuel filters from vehicle maintenance or equipment shops on Fort Rucker. Control of EMS procedures is addressed in procedure EMS-P002, Document Control. 2.0 SCOPE This procedure applies to all vehicles and equipment operations that generate used oil and fuel filters, including those activities located at facilities outside the contiguous boundary of Fort Rucker’s main cantonment area. The requirements of this procedure are applicable to all military, civilian, tenant, and contract personnel at Fort Rucker utilizing installation resources to manage these waste streams. Tenants or contractors utilizing a separate contractor for POL disposal/recycling should coordinate with DPW-ENRD if their operations make it necessary to deviate from this procedure. 3.0 DEFINITIONS

TERM DEFINITION DPW-ENRD Directorate of Public Works, Environmental and Natural Resources

Division, located in Building 1121, telephone number 334-255-1024.HMCC Hazardous Material Control Center, located in Building 1315,

telephone number 334-598-1311. HWMP Hazardous Waste Management Plan - documents personnel and

procedures to ensure each step in the "cradle-to-grave" management of hazardous or other special wastes is carried out in a consistent manner and in accordance with regulatory requirements. Procedures are either referenced or included in the HWMP, as necessary, to provide documented hazardous and other special waste management instructions, from the time of waste generation until it is transported offsite for reuse or disposal.

4.0 RESPONSIBILITIES

4.1 It is the responsibility of each activity to follow proper procedures in accordance with this work instruction. Any deviation from this procedure due to utilization of a different disposal/recycling contractor should be coordinated with DPW-ENRD to ensure continued environmental protection.







4.2 DPW-ENRD responsibilities include periodically performing waste and

recycling drum surveys to validate conformance with this procedure. DPW-ENRD will conduct formal inspections as described in EMS-P006, Internal Auditing.

5.0 PROCEDURE

5.1 Management of Used Oil Filters 5.1.1 Non-metal filters (from all engines except gasoline) must be drained

of free flowing liquid, then may be disposed in regular trash. 5.1.2 Metal filters:

5.1.2.1 Metal filters may be returned to the HMCC directly or placed in designated blue totes for pick up by HMCC delivery personnel.

5.1.2.2 Metal filters will be drained, crushed and recycled by the HMCC. The HMCC will do the following: (a) Remove free-flowing oil through gravity and hot-drain into

proper used oil container. (b) Crush filters in a suitable machine so that the scrap metal

can be recycled and the used oil captured and transferred into the used oil accumulation container or tank (labeled “used oil”).

(c) Place crushed metal filters into collection containers for scrap metal recycling.

(d) Do not place any filters in the scrap metal collection containers unless they have been crushed.

(e) Check bottom of collection container for free liquid. Pump out or absorb any oil that has accumulated to avoid a leak or spill. It is recommended that collection containers be lined with absorbent pads to absorb residual oil from filters once crushed.

(f) Any containers of used filters awaiting crushing must be marked with the words “Used Oil Filters”. Additional words may also be used in conjunction with “Used Oil Filters” if desired for clarity, such as “Used Oil Filters for Recycling”.

(g) All containers must be closed except when adding or removing filters.

(h) All used oil containers or tanks must also be marked “Used Oil” and managed per current procedures for used oil management.







5.2 Management of Fuel Filters (all fuels except gasoline) 5.2.1 For all used F24 or diesel filters, handle per instructions for used metal

and non-metal oil filters above. 5.2.2 Drain filters and manage used fuel separately from used oil.

5.3 Management of Gasoline Filters

5.3.1 Drain into separate container designated for gasoline only until there is no free flowing liquid or seepage from filters.

5.3.2 Collect in container separately from other waste streams marked “used gasoline fuel filters – pending analysis”. Contact DPW-ENRD so that laboratory sampling and analysis of the filters can be conducted.

5.3.3 If laboratory testing confirms that they are below hazardous waste action levels, they may be disposed in regular trash after being drained of all free flowing liquid.

5.3.4 If laboratory testing confirms that they are hazardous waste, they will be managed per all existing Fort Rucker hazardous waste management procedures.

5.4 Management of Terne-Plated Filters

5.4.1 Different handling and disposal requirements may apply to filters from buses, semi-tractors, heavy equipment, or construction equipment. Generators of filters from these equipment types must contact DPW-ENRD to obtain specific guidance. The reason for this is to confirm if filters are terne-plated. Terne (a lead-tin alloy) serves as a plating on some larger filters which may require different handling as hazardous waste. Light-duty automobiles and trucks typically use non-terne-plated filters.

6.0 FORMS / RECORDS

DD 1348-1A, Issue Release/Receipt Document

7.0 REFERENCES EMS-P002, Document Control EMS-P006, Internal Auditing EMS-WI-SW001, Waste Turn-In Procedure Hazardous Waste Management Plan (HWMP) Alabama Administrative Code 335-14-17-.02(1)(c) 40 CFR 261.4(b)(13)

Appendix S EMS-WI-SW003, Used Lamps Management



Revision Date 8 SEP 16

Title: Used Lamps Management




1.0 PURPOSE This procedure defines the requirements for management of used lamps on Fort Rucker. Control of EMS procedures is addressed in procedure EMS-P002, Document Control. 2.0 SCOPE This procedure applies to all Fort Rucker operations that generate used lamps, including those activities located at facilities outside the contiguous boundary of the installation. The requirements of this procedure are applicable to all military, civilian and contract personnel at Fort Rucker. 3.0 DEFINITIONS

TERM DEFINITION Accumulation Start Date (ASD)


DPW-ENRD

Directorate of Public Works, Environmental and Natural Resources Division, located in Bldg 1121, telephone number 334-255-1024.

Environmental Officer / EPOC

The Environmental Officer / EPOC is the main contact within an organization for ensuring continued conformance with the EMS and compliance with regulatory requirements. These personnel are assigned in accordance with GC Policy Memo 13-35.

Green-Tipped Lamp

A fluorescent lamp with low mercury content. Typically, the lamp has green tips, green marking, or green writing stating “low mercury content” on the lamp.

HMCC Hazardous Material Control Center, located in Bldg 1315, telephone number 334-598-1311.

90-HWAS / 180-HWAS Less Than 90-Day/180-Day Hazardous Waste Accumulation Site

HWMP The Fort Rucker Hazardous Waste Management Plan documents procedures to ensure each step in the "cradle-to-grave" management of wastes with hazardous characteristics is carried out in a consistent manner and in accordance with (IAW) regulatory requirements. Procedures are either referenced or included in the HWMP, as necessary, to provide documented waste management instructions, from the time of waste generation until it is transported offsite for reuse or disposal.

IAW In Accordance With







TERM DEFINITION Used Lamps Used lamps, also referred to as "universal waste lamp", means

the bulb or tube portion of an electric lighting device. Examples of common universal waste electric lamps include, but are not limited to, fluorescent lamps of various sizes, high intensity discharge (HID), neon, mercury vapor, high pressure sodium, and metal halide lamps.

Universal Waste Universal wastes are hazardous wastes that are subject to less stringent hazardous waste management regulations, particularly by allowing more time for accumulation of these wastes in order to facilitate appropriate recycling or disposal. Four types of waste are covered under the universal waste regulations: batteries, lamps, mercury-containing equipment, and pesticides.

4.0 RESPONSIBILITIES It is the responsibility of each unit, organization or contractor working at Fort Rucker to follow these procedures. 5.0 PROCEDURE

5.1 Purchase 5.1.1 IAW Green Procurement Guidance, environmentally friendly items will be

purchased where feasible. Green-tipped lamps will be purchased/used where available.

5.1.2 The most common types of green-tipped lamps will be made available through Self Help, Building 1427, either one at a time replacement quantities, or by the box. Individual credit card holders are responsible for purchasing replacement green-tipped lamps where practical.

5.2 Management of Used Lamps:

5.2.1 All used lamps, including green-tipped lamps, will be managed as Universal Waste lamps.

5.2.2 Always open a new lamp box by the pull flap. Never cut off flaps or “window cut” boxes. When all new lamps are used and the box is empty, this box now becomes suitable for used lamp accumulation.

5.2.3 Used Lamp Management: 5.2.3.1 Lamps that are no longer usable are Universal Waste according to

the applicable regulations. 5.2.3.2 Accumulating used lamps:

(a) When a used lamp is first placed into a box or fiber drum, that container must be labeled (please see the HWMP for example







labels and verbiage). The label must meet the following requirements:

-all labels must be visible from the front of the box -all labels must be right side up -all labels must contain:

the words "UNIVERSAL WASTE", and the words “Used Lamps”, and the accumulation start date (ASD) (the date the first used

lamp was placed in the container). (b) Box(es) or fiber drums containing used lamps must be kept

closed except when lamps are being added to it. (c) Filling a used lamp box on a 30-45 degree angle will help in

placing lamps in layer fashion, allowing more to be placed in the box. Do not stand 4’ and 8’ boxes on their end.

(d) Lamps must be segregated by type and by size. For example, all 4-foot fluorescent lamps should be in a separate box from 8-foot fluorescent lamps, from compact fluorescent lamps (CFLs), etc.

(e) Individual used lamps or partially-filled containers (boxes or fiber drums) may be turned in to the HMCC, each work day between 0730 and 1600.

(f) Full boxes or fiber drums of used lamps are to be accompanied by a completed DD Form 1348-1A, including a total bulb count. No container should be maintained longer than 6-months from the ASD, regardless if full or not. Note that full used lamp containers may be turned in to the Cairns 90-HWAS, the Shell 180-HWAS or the Fort Rucker 90-HWAS (Bldg 1207) on Thursdays or by appointment by calling the HMCC at 334-598-1311.

5.3 Broken Mercury-Containing Used Lamp Clean-Up

When handling used lamps, use caution to avoid breaking the lamps as mercury will be released into the atmosphere. If a mercury-containing lamp is broken, the lamp(s) should be managed as hazardous waste. Please reference the HWMP for detailed management procedures. Note that your units, organizations or contractors Environmental Officer, EPOC, or Hazardous Waste Manager are typically the only individuals trained within your organization to manage a hazardous waste. If one of these individuals is not available to clean up the broken mercury lamp, please notify the Fire Department (911) and the Service Order Desk (255-9041).

If a lamp breaks, follow the procedure below: 5.3.1 If not trained in hazardous waste cleanup, please call 911 and the Service

Order Desk 255-9041 for assistance. Note that if the lamp is green-tipped







any individual may clean-up the broken glass since little mercury remains. If one cannot determine if the lamp is a low mercury lamp, the broken lamp is to be managed as a mercury-containing lamp.

5.3.2 Keep all people away from the breakage area so mercury-containing powder is not tracked into other areas. Mercury may be bound to the broken glass and powder.

5.3.3 Air out the area for 15 minutes by opening a door or window to an outside area. Keep well ventilated. This allows mercury vapors to dissipate.

5.3.4 Assemble necessary supplies: latex gloves, tweezers, tape, index cards/cardboard, damp paper towels, and a plastic container.

5.3.5 Wearing the gloves, carefully pick up any broken glass and place in puncture resistant container. Tweezers can be used to safely pick up broken glass. Tape can be used to pick up small pieces of glass and powder residue left on spill surface.

5.3.6 Use two pieces of cardboard to push together remaining powder and fragments of glass. Finish cleanup by wiping with damp paper towels.

5.3.7 Important: Do Not Vacuum!! Mercury residue in the vacuum is heated up and can vaporize when the vacuum is used again.

5.3.8 After clean-up is complete, place contaminated clean-up equipment along with any other materials that came in contact with the mercury powder into the puncture resistant container.

5.3.9 Label all containers “Hazardous Waste-Contains Mercury.” 5.3.10 Store container(s) on a corrosion-proof surface, inside a structure that is

protected from the weather. 5.3.11 Complete a DD Form 1348-1A for turn-in as described in the Fort Rucker

HWMP and dispose as a hazardous waste. 5.3.12 Contact Misty Howell at 334-255-1024 for more information.

Spills of one pound (34 ml or approximately two tablespoons) or more are to be reported to DPW-ENRD at 255-1024 or 255-1657 immediately. 6.0 FORMS AND RECORDS DD Form 1348-1A 7.0 REFERENCES Hazardous Waste Management Plan EMS-P002, Document Control

Appendix T

USAACE Form 2719, Site Specific Spill Plan

SITE SPECIFIC SPILL PLAN For use of this form, see the Installation Spill Contingency Plan; the proponent is DPW-ENRD

USAACE FORM 2719 (24JUL15) Page 1 of 12 THIS IS A CONTROLLED DOCUMENT PREVIOUS EDITION IS OBSOLETE VERIFY THE LATEST VERSION ONLINE

POST THIS PAGE PROMINENTLY AT EACH HAZARDOUS WASTE SATELLITE ACCUMULATION POINT, 90-DAY HW SITE, HAZARDOUS MATERIAL STORAGE AREA, AND SPCC CONTAINER

STORAGE AREA

ORGANIZATION’S SPILL RESPONSE POINTS OF CONTACT

PRIMARY: PHONE:

ALTERNATE: PHONE:

APPROPRIATE FIRE DEPT / CRASH NUMBER:

LOCATION OF COMPLETE SITE SPECIFIC SPILL PLAN: TYPE OF MATERIAL / WASTE STORED (general description of what is stored in the area)

LOCATION OF MSDS/SDS / ADDITIONAL WASTE INFORMATION

LOCATION OF NEAREST SPILL KIT / SUPPLIES

Spill Response

Call 911 for all spills to the environment (water, soil, drains)

Remove the source of the spill

Envelop spilled material on ground

Absorb spilled material; clean up soil

Containerize used absorbent & soil

Transmit a report of the spill



MAINTAIN THE REMAINDER OF THE PLAN IN THE AREA DESIGNATED ON PG 1, WHICH MUST BE EASILY ACCESIBLE, AT EACH FACILITY WITH A HWSAP, 90-HWAS, HM STORAGE AREA, OR SPCC CONTAINER

STORAGE AREA

SECTION 1. ORGANIZATION IDENTIFICATION

Organization:

Commander/Supervisor:

Environmental Officer/EPOC:

Secondary POC:

Location/SPCC Plan Figure (i.e., South Fort Rucker)

Bldg. Number and/or Shop Name

Date plan prepared/updated:

Signature of Commander/Supervisor Signature of Environmental Officer/EPOC SECTION 2. PLAN REVIEW AND AMENDMENT

This plan will be reviewed for adequacy and accuracy and updated at least annually. Upon issuance of a new version of this EMS form, organizations may wait for their annual review to update their Site Specific Spill Plan to reflect any changes to this form. SECTION 3. PURPOSE This Site Specific Spill Plan provides policy, guidance, and procedures for the prevention, control, containment, and response to spills of oil products and hazardous substances within the organization’s facilities. It has been prepared in compliance with the requirements of the Spill Prevention, Control and Countermeasures (SPCC) Plan and the Installation Spill Contingency Plan (ISCP). This plan also meets the requirements for spill response procedures contained within the Hazardous Waste Management Plan (HWMP). SECTION 4. DEFINITIONS A. Acronyms

90-HWAS Less than 90-Day Hazardous Waste Accumulation Site ADEM Alabama Department of Environmental Management DPW Directorate of Public Works EMS Environmental Management System ENRD Environmental and Natural Resources Division EPOC Environmental Point of Contact



HWMP Hazardous Waste Management Plan HWSAP Hazardous Waste Satellite Accumulation Point ISCP Installation Spill Contingency Plan MSDS Material Safety Data Sheet OSC On Scene Coordinator RCRA Resource Conservation and Recovery Act RQ Reportable Quantity SDS Safety Data Sheet SPCC Spill Prevention, Control, and Countermeasures SWPPP Stormwater Pollution Prevention Plan

B. Spill: A spill is broadly defined as a release of any kind of a petroleum product (fuel or oil) or hazardous substance to the environment. Spill reaction is based largely on the nature, quantity, and location of the material spilled. For the purposes of this plan, the following spill classifications will apply:

1. Small Priming Spill - A spill that covers less than 18 inches in all directions.

2. Small Spill - A spill that extends less than 10 feet in any direction, covers less than 50 square feet, and is not continuous.

3. Large Spill - A spill that extends farther than 10 feet in any direction, covers an area in excess of 50 square feet or is continuous (e.g., a leaking tank).

C. Significant spill: A significant spill is defined as an uncontained release to the land,

water or air in excess of any of the following quantities:

1. For hazardous waste or hazardous material identified as a result of inclusion in the Title III List of Lists (ISCP Appendix H), any quantity in excess of the reportable quantity (RQ) listed in the Title III List of Lists.

2. For oil or liquid or semi-liquid hazardous material or hazardous waste, in excess of 400 liters (110 gallons). For purposes of reporting to Federal, State, and local authorities, a reportable oil spill is defined as any spill that exceeds 25-gallons (ADEM requirement) or that reaches a stream, creek, river or any other body of water in harmful quantities (see definition above).

3. For other solid hazardous material, in excess of 225 kg (500 lbs.).

4. For combinations of oil and liquid, semi-liquid and solid hazardous materials or hazardous waste, in excess of 340 kg (750 lbs.).

5. If a spill is contained inside an impervious berm, or on a nonporous surface, or inside a building and is not volatilized and is cleaned up, the spill is considered a contained release and is not considered a significant spill.



6. For releases to the air, substances in (but not limited to) the Title III List of Lists in quantities that may as a result of short-term exposure cause death, injury or property damage due to their toxicity, reactivity, flammability, volatility or corrosivity.

SECTION 5. RESPONSIBILITIES A. Commander/Supervisor:

1. Implement this plan.

2. Review and sign the plan when it is prepared or updated.

3. Appoint an organization Environmental Officer/EPOC to carry out the duties associated with this plan.

B. Environmental Officer/EPOC:

1. Update and maintain this plan as needed based on changes in organization mission, function, and facilities. At a minimum, this plan will be updated annually.

2. Requisition, store, maintain and issue materials used for the cleanup of spills within the organization’s area.

3. Respond to, evaluate, classify and record data on all spills within the unit.

4. Contact the Fort Rucker Fire Department for all oil spills and spills of hazardous substances released to the land, water or air. Provide all information concerning the spill event as well as any determinations made on the classification of the spill.

5. Document all spills within the organization and maintain an appropriate file.

6. Develop and implement a training program for organizational personnel.

7. Conduct inspections required by the SPCC Plan and the Hazardous Waste Management Plan.

SECTION 6. ORGANIZATIONAL ACTIVITIES / POTENTIAL SPILL SOURCES Attach hazardous material inventory, SPCC inventory, and/or waste profile information or fill out the following table with applicable information ONLY for materials/wastes stored in the facility listed in Section 1. Do NOT attach AUL or waste profiles for materials/wastes that are stored in facilities covered by another Site Specific Spill Plan.



MATERIAL / WASTE STORED CONTAINER

SIZE STORAGE LOCATION



SECTION 7. FACILITY DESCRIPTION

Describe the facility (i.e. steel frame, brick, square footage, year built, type of operation within building and outside the building, number and location of flammable storage, HWSAPs, etc.). Attach a map/drawing that shows storage locations (maps are available in the SPCC Plan and the SWPPP showing higher risk storage locations).

SECTION 8. SPILL PREVENTION

1. Use drip pans under all parked vehicles and equipment that leak.

2. Use drip pans under all hose connections that leak.

3. Close all valves before disconnecting/connecting any hoses.

4. Drain all parts before moving away from parts cleaning equipment.

5. Provide storage with secondary containment for all oil and hazardous substances stored in 55-gallon or larger containers.

6. Employ good housekeeping procedures to maintain work areas.



SECTION 9. LOCATION AND DESCRIPTION OF SPILL RESPONSE EQUIPMENT Materials for cleanup of spills should be readily available. These materials should include items such as kitty litter, oil absorbent pads, dry sweep, oil socks/booms, shovel, and gloves. (ONLY include supplies stored in the facility listed in Section 1) A. Spill Containment Equipment:

B. Fire Control Equipment

C. Personal Protective Equipment

D. First Aid and/or Medical Supplies

E. Emergency Decontamination Equipment

F. Emergency Communication and Alarm System



SECTION 10. POSSIBLE SPILL ROUTES

The following spill routes are possible within the organization’s area of responsibility (attach a figure/map as necessary – spill routes are depicted on figures in SPCC Plan and SWPPP for higher risk storage areas):

LOCATION DESCRIPTION

(i.e., shop name)

BLDG NUMBER

INSIDE OR OUTSIDE?

SPILL ROUTE (i.e., remain on the floor until

cleaned up; flow toward the south)

SECTION 11. SPILL RESPONSE / CLEANUP In the event of a spill the following actions should be taken. The order of the actions will depend on the existing conditions.

1. EVACUATE AREA, IF NECESSARY

2. NOTIFY THE FIRE DEPARTMENT, EXT 911 or 255-0044

3. NOTIFY SUPERVISOR , EXT

4. CHECK CAUSE AND STOP SOURCE OF SPILL, WHEN POSSIBLE, WITHOUT UNDUE RISK OF PERSONNEL INJURY.

5. MAKE SPILL SCENE OFF LIMITS TO UNAUTHORIZED PERSONNEL AND VEHICLES

6. RESTRICT ALL SOURCES OF IGNITION

7. COVER DRAINS IN AREA OF SPILL, WITHOUT UNDUE RISK OF PERSONNEL INJURY



8. REPORT TO ON-SCENE-COORDINATOR (OSC) WITH MSDSs/SDSs

When notifying the fire department, the following information should be provided if known or can reasonably be determined.

1. Location, time, and type of incident (spill, fire, injury, etc.).

2. Name and quantity of spilled material and the rate of release.

3. Provide MSDS/SDS for spilled material, if available.

4. Direction of the spill, vapor, or smoke release.

5. Fire and/or explosion possibility.

6. Coverage area of spill and the intensity of any fire or explosion.

7. The extent of injuries, if any.

SECTION 12. SPECIAL PRECAUTIONARY MEASURES A. Designated Evacuation Route and Distance (attach map if necessary)

B. Specified Meeting Point

C. Consult MSDS/SDS for firefighting and first aid procedures. MSDS/SDS location:

SECTION 13. POSTING REQUIRMENTS A. The first page of the Site-Specific Spill Plan will be printed and will be posted in a

prominent place adjacent to each HWSAP, 90-HWAS, HM Storage Area, and SPCC Container Storage Area. The remainder of the plan will be placed in the location designated on page 1 within the building or shop so that everyone involved in working at the site will be able to access and implement its contents.



B. A signed copy, along with the ISCP, will be maintained by the Environmental Officer/EPOC along with a listing of all applicable MSDS/SDS.

C. Documentation of spills to the ground or water is to be provided to the DPW-ENRD within 24-hours of the incident.

SECTION 14. INSPECTION PROGRAM A. The Environmental Officer/EPOC will conduct monthly inspections (weekly for used

products) on all oil containers 55-gallons or larger to ensure compliance with this plan, to identify deficiencies and to make recommendations on corrective actions required. These inspections will be documented using USAACE Form 2711 SPCC Container Inspection Form. Copies of all inspection forms will be forwarded to DPW-ENRD at the end of each month.

B. The HWSAP Manager or the 90-HWAS Manager will conduct inspections of all

hazardous waste containers to ensure compliance with this plan, to identify deficiencies and to make recommendations on corrective actions required. These inspections will be documented using USAACE Form 2725 Hazardous Waste Satellite Accumulation Point Inspection Checklist or USAACE Form 2726 Less than 90-Day Hazardous Waste Accumulation Site Inspection Log.

C. The Environmental Officer / EPOC may conduct inspections of all hazardous material

storage areas and potential stormwater issues using the applicable sections of USAACE Form 2717 Environmental Compliance Inspection Checklist. These inspections are conducted quarterly by DPW-ENRD, but organizations should consider conducting self-inspections to help ensure continued compliance.

SECTION 15. TRAINING PROGRAM A. The Environmental Officer/EPOC will receive training on the SPCC Plan and ISCP

from the DPW-ENRD within six months of assignment of duties and at least annually thereafter.

B. Training on the organization’s Site Specific Spill Plan, the Fort Rucker SPCC Plan, and

the Fort Rucker ISCP are required for all oil handling personnel. 1. This training should include:

a. Types of hazardous and toxic substances used in the organization. b. Methods of retaining spills. c. Methods of recovering spilled materials. d. Disposition of contaminated soil, absorbent material and recovered

substance. e. Restoration of contaminated areas to their former condition.



2. All such personnel will receive this training within 30 days of assignment of appropriate duties and at least annually thereafter.

C. Training is required for personnel who handle hazardous waste and for managers and supervisors of personnel who handle hazardous waste, including those who maintain and operate HWSAPs / 90-HWAS (HWSAP / 90-HWAS Managers).

1. Initial personnel training is required to be completed within six months of the

individual being assigned to hazardous waste handling duties. 2. Training will focus on how to safely manage and operate a HWSAP / 90-HWAS.

It must enable employees involved with hazardous waste operations to perform their duties without endangering themselves or other employees. Emphasis should be given to the emergency response, use of protective equipment and clothing, recognition of hazardous waste, hazards of waste encountered, and an overview of RCRA regulations relating to employees.

3. DPW-ENRD offers a two hour HWSAP Manager Course and a two hour 90-

HWAS Manager Course that are required annually for all personnel assigned as a primary or alternate HWSAP / 90-HWAS manager.

D. The Environmental Officer/EPOC will maintain records of training. Records on

individuals will be maintained on file for a minimum of three years after departing the organization. A copy of the individual’s training record may be provided to the individual upon their departure.

SECTION 16. YEARLY EXERCISE This plan will be exercised within the organization at least yearly through the staging of a mock spill. The Environmental Officer/EPOC will develop, supervise, evaluate, and document the exercise to test the understanding by the organization of the plan, their ability to appropriately respond to a spill, and the overall effectiveness of the plan. SECTION 17. DOCUMENTATION A. All spills will be documented/reported using USAACE Form 2718 Spill Notification

Report. These records will be maintained for a minimum of three years. B. All inspections conducted in accordance with the ISCP, the SPCC Plan, and the

HWMP will be documented using appropriate EMS forms. These records will be maintained for a minimum of three years.

C. All training records will be maintained for a minimum of three years.



D. The Environmental Officer/EPOC will develop and maintain an Environmental Binder relating to environmental activities within the organization. The file will contain all information specified in EMS-WI-EM001, Environmental Binder Work Instruction.

HAZARDOUS WASTE MANAGEMENT PLAN UNITED ... Rucker...Hazardous Waste Program Manager 334-255-1024...

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