Memorandum 80-5 as the responsibility of each branch] including the wastes listed below: 1. toxicological, biological, radiological, and lethal chemical warfare materials which, by U.S. law, must be destroyed 2. material that cannot be disposed of in its present form because of military regulations, e.g., consecrated religious items and cryptographic equipment 3. municipal-type garbage, trash, and refuse resulting from 4. residential, institutional, commercial, agricultural, and community activities, which the facilities engineer routinely collects contractor-generated materials that are the contractor's 5. sludges resulting from municipal-type wastewater treatment 6. sludges and residues generated as a result of industrial plant 7. refuse and other discarded materials which result from mining, 8. unique wastes and residues of a nonrecurring nature which research DLA delegated the operational responsibilities to DRMS, DRMR, and DRMO in assisting DoD installations in the disposal of hazardous wastes and other excess or surplus properties. Once DRMO takes custody of the hazardous wastes, one of their hazardous waste contractors is notified for pickup within 90 days. DRMO's responsibilities are given below: 1. Ensure that all containers are properly packaged, labeled, and 2. Place appropriate shipping labels and vehicle placards in 3. Transport hazardous wastes to an approved Class I landfill for 4.5.3.5 Installation Responsibilities. At the installation level, the environmental office is responsible for managing the hazardous waste program. This task involves handling and disposal of hazardous wastes. Basically, the procedures for handling hazardous wastes are as follows: 1. Properly segregate and containerize all hazardous wastes. 2. Label each container and indicate EPA identification number. 3. Prepare disposal turn-in document DD Form 1348-1. 4. Prepare hazardous waste manifest. 4.5.4 Hazardous Waste Management Plan. The Hazardous Waste Management Plan (HWMP) provides guidance to installation personnel in handling and storage of hazardous wastes consistent with regulatory requirements. Guidelines for preparing an HWMP are contained in 40 CFR 260-270. In addition, state and local regulations must also be complied with, if more stringent than the federal requirements. 4.5.4.1 Scope. The scope of the HWMP depends on the installation's hazardous waste generation rates. This section is provided only for guidance and is not meant to be a complete discussion of HWMPs. Typically, the HWMP shall contain the following items: 2. Regulations - a summary of the applicable federal, state, and local regulatory requirements. 3. Responsibility duties and responsibilities of all personnel involved with the management of the HWMP are listed. 4. Organizational Chart - an organizational structure 5. Hazardous Waste Inventory - a compilation of the quantities of 6. Location Map - a base map indicating the boundaries and all areas where hazardous wastes are generated and accumulated. 7. Standard Operating Procedures detailed explanation of the correct procedures concerning the generation, containerization, collection, labeling, marking, recordkeeping, packaging, handling, storage, treatment, transportation, and disposal of hazardous waste. This is the most critical section in the HWMP. 8. Inspection Plan - a well-organized plan is required to ensure that the hazardous waste management program is implemented correctly and the installation is complying with all pertinent regulations. 9. Training Plan personnel directly involved in hazardous waste management are required to be trained so they can successfully perform their duties. 10. Spill Contingency Plan - a description of actions installation personnel must take to respond to a spill of hazardous wastes. This is a requirement for all military installations and will most likely If an installation wants to operate a treatment, storage, and disposal (TSD) facility, the installation must prepare a hazardous waste analysis plan, facility inspection plan, facility contingency plan, facility closure plan, and facility post-closure plan, depending on the facility, pursuant to 40 CFR 264 requirements. These plans must be approved by EPA prior to issuance of TSD permit. 4.5.4.2 Directives. DoD directives supporting RCRA regulations are issued to the services for compliance. These directives, such as the Solid and Hazardous Waste Management Collection, Disposal, Resource Recovery, and Recycling Program; DoD Directive 4165.60; Hazardous Waste Minimization Program; Used Solvent Elimination Program; and other related hazardous waste issues are incorporated into the HWMP for compliance by the installations. 4.5.5 Hazardous Waste Handling, Storage, and Disposal 4.5.5.1 Segregation is one of the most important factors required to ensure a successful hazardous waste management program. To minimize contamination, use the original empty product can or container (provided it is in good condition) to collect the hazardous wastes. Containers shall be small enough to easily be handled and filled-up in less than 90 days. This is important if the installation does not have a permitted storage facility. 4.5.5.2 Store flammable hazardous wastes in Department of Transportation (DOT)-approved containers. Ensure these safety cans are properly grounded when used for storage of flammable solvents. In addition, check that containers are fully grounded when transferring flammable hazardous wastes. 4.5.5.3 Hazardous wastes must be packaged correctly so that they can be transported and stored safely pending disposal. Wastes must be packaged in tightly closed containers, either in the original container or in a DOT-approved container. Most wastes should be collected in the original container. The containers must show no signs of deterioration or damage. The container material of construction must be chemically compatible with the contents. 4.5.5.4 Labeling and Color Coding. A good segregation program requires proper identification of hazardous waste for both collection and subsequent handling. This is done in the following manner: Label containers on the side with the name, MILSPEC and FSN (Federal Place a sign (wood or metal) on the designated collection area or hang it over the collected containers. Use color coding of drums/containers to identify different 4.5.5.5 Manifesting. A generator who transports, or offers for transportation, hazardous waste for offsite treatment must prepare a manifest OMB control number 2000-0404 on EPA Form 8700-22, and if necessary an EPA Form 8700-22A according to instructions in the Appendix of 40 CFR 62. The manifest will contain: 1. 2. 3. generator's U.S. EPA identification number generator's name, mailing address, and phone number name and U.S. EPA identification number for each transporter 4. designated disposal facility name, site address, and U.S. EPA identification number 4.5.5.6 Storage. Waste generators may accumulate hazardous waste onsite without a permit for 90 days or less after the date of generation. The accumulation date normally starts when a waste is first placed into a container or unused material is declared as waste. An exception to the regulation is allowed if wastes are collected at or near the point of generation. A satellite storage area is the waste collection area at or near the point of generation. The accumulation start date for wastes collected in this manner is the date the container is full or the quantity of hazardous waste exceeds 55 gal or the quantity of acutely toxic waste exceeds 1 qt. Hazardous wastes generated at the shops are collected in appropriately labeled cans or drums adjacent to the work areas. When they become full, they are moved to a central storage area for accumulation of less than 90 days. DRMO takes custody of the hazardous materials and hazardous waste in accordance with DoD 4160.21-M. If the DRMO does not have a permitted facility, the installation retains physical custody of waste while DRMO takes "paper" custody and begins to arrange for disposal. 4.5.5.7 Disposal. Hazardous waste and hazardous materials that cannot be treated or recycled onsite are sent to DRMO in accordance with DoD 4160.21-M. Hazardous materials and hazardous waste that cannot be reused or sold by DRMS are disposed of by service contract. DRMS employs contractors to provide a disposal service, which includes transportation and ultimate disposal. It may also include packaging and testing if required. DRMO services through the DRMO contract provide timely removals, discounted prices based on volume, and balanced interest for small generators in remote locations equal to large generators located on main transportation routes. DRMS surveillance of contractor performance reduces the liability for DoD. 4.5.6 Treatment Alternatives. Hazardous wastes generated at the installation's industrial facilities are treated either onsite or offsite. Typical hazardous wastes subjected to treatment are solvents, plating wastes, aircraft paint stripping wastes, and acids. Used petroleum products may or may not be considered hazardous depending on the nature of their contaminants. DoD established the Used Solvent Elimination Program and the Hazardous Waste Minimization Program to provide direction and guidance in reducing hazardous wastes generation. 4.5.7 Petroleum Products 4.5.7.1 Used petroleum products represent another source of revenue for recycling installations provided they are not contaminated. When contaminated, they are somewhat special wastes because in many cases they can be re-used. For example, lube oil which does not quite meet specifications for fighter aircraft might be suitable for maintenance equipment. Re-use is a higher priority than recycling and must be considered before submitting a product for recycling. 4.5.7.2 DoD Directive 4165.60 also addresses the recycling of used petroleum products. AFR 19-14 addresses Air Force policies, duties, accounting guidelines, and documentation instructions for recycling of and/or recovering liquid petroleum products. 1. Installations that generate used lubricating oil and other waste petroleum shall take the following steps: a. b. C. Maximize the sale through DRMO of recovered used lubricating oil Because re-refining may not be economically feasible in some areas of the U.S., used lubricating oil and other waste petroleum may be burned as a fuel or fuel supplement in boilers if no reasonable arrangements can be made for recovery by rerefining. Burning used oil is consistent with the general national conservation principle to conserve our petroleum resources and to preserve the quality of our natural environment. In this regard, the economics of energy recovery alone are not to be considered as sufficient justification for burning waste petroleum products. Environmental effects and conservation also need to be considered as high priority factors in making the final decision. Report waste inventories as generated and anticipated annual generations, where applicable, to the servicing DRMO for ultimate disposition. d. Conduct laboratory analysis, as necessary, to identify abnormal contaminants. If contaminants exceed the used oil specifications, the used oil becomes a hazardous waste and can only be burned in a permitted facility. |