SOP Spill

STANDING OPERATING 17 May 2012
PROCEDURE

STANDARD OPERATING PROCEDURE FOR COLLECTION, STORAGE, AND TURN-IN
OF HAZARDOUS WASTE AND NON-REGULATED WASTE,
9TH MISSION SUPPORT COMMAND/THEATER SUPPORT GROUP (MSC/TSG) MAINTENANCE FACILITIES

1. Definition. The 9th MSC/TSG Maintenance Facilities include the following locations: Fort Shafter Flats, Honolulu, Hawaii; PFC Kaoru Moto, Wailuku, Hawaii; SFC Minoru Kunieda, Hilo, Hawaii; and SSG Robert Kuroda (LSV7), Bishops Point, Hawaii; Pele USARC, Pago Pago, American Samoa; MSG Vincente Dydasco USARC, Radio Barrigada, Guam; Tanapag USARC, Puerto Rico, Saipan.

2. Purpose. This Standing Operating Procedure (SOP) provides procedures for the proper collection, storage, and turn-in of hazardous waste (HW) and non-regulated waste at the 9th MSC/TSG Maintenance Facilities, Hazardous Waste Shop Storage Point (HWSSP), Recyclable Material Shop Storage Point (RMSSP) and all operational areas.

3. Scope. Provisions of this SOP are applicable to all of the 9th MSC/TSG Maintenance Facilities operations. This SOP implements requirements of the Resource Conservation and Recovery Act, Subpart C. Failure to comply fully with the requirements of this plan could result in civil/criminal penalties.

3. References.

a. 40 Code of Federal Regulations (CFR), Parts 260 to 280.

b. 49 Code of Federal Regulations, Parts 170 to 179.

c. 29 Code of Federal Regulations, Part 1910.1200.

d. Hawaii Administrative Rules (HAR), Title 11, Chapters 260 to 280.

e. Army Regulation 200-1, Environmental Protection and Enhancement, Dec 2007.

f. Army Regulation 420-1, Army Facilities Management, 12 Feb 2008.

g. DOD 4160.21-M, Defense Reutilization and Marketing Manual (Hazardous Property Management Chapter IX), Aug 97.

h. DA Pam 200-1, 9 RRC [MSC/TSG] Installation Hazardous Waste Management Plan (IHWMP), August 2003.

i. Policy Memorandum, USAG-HI-10, Environmental Policy, 22 Jan 2008.

j. Policy Memorandum, USAG-HI-4, Environmental Compliance and Protection Program,
22 Jan 08.

k. Chemistry of Hazardous Materials, Eugene Meyer, Prentice-Hall, Inc., 1990.

l. Policy Memorandum, USAG-HI-7, Management of Disposal of Flameless Ration Heaters,
20 Aug 2008.

o. Rechargeable Battery Implementation Policy, 29 Dec 2003.

p. Management of Used Oil Containers, 27 Feb 2004

q. Authorized Use List Memorandum, 29 Dec 2005

4. Responsibilities.

a. 9th MSC/TSG Environmental Division.

(1) Train and provide assistance to activity Environmental Compliance Officers (ECOs).

(2) Conduct inspections, at least annually, to monitor compliance with this SOP and EPA HW regulations. Make recommendations for corrective actions or procedural changes when necessary or advisable.

(3) Coordinate knowledge and response to EPA inspections immediately with the command. Prepare responses to EPA inspection deficiencies.

(4) Keep the command advised of results of inspections.

(5) Initiate measures to minimize the generation of HW.

(6) Monitor HW generated on 9th MSC/TSG Maintenance Facilities (for both tenant and non-tenant circumstances).

(7) Provide for analysis of waste to determine if it is hazardous as defined in Federal, State, or local laws and regulations consistent with requirements of 40 CFR 264.13.

(8) Receive and submit disposal requests to DRMO and/or other approved contracting agencies. Sign all documentation (as applicable) and retain on-site for a period of 3 years.

(a) Lab Analysis for HW accumulated (if applicable). (c) MSDSs or HMMS profile for all HW accumulated. (d) DD Form 1348-1A for all HW turned-in (e) DRMS Form 1930 Hazardous Waste Profile Sheet/HMMS Profile Sheet

(9) Develop programs for compliance projects.

(10) Review Authorized Use List for hazardous materials.

(11) Report spills to regulators if reportable quantities are exceeded.

b. Each Unit working within the 9th MSC/TSG Maintenance Facility, Environmental Compliance Officer (ECO) and Alternate.

(1) Must assign a primary and an alternate ECO on duty appointment orders (in accordance with Enclosure 1). Provide a copy of these appointment orders to the 9th MSC/TSG, Environmental Compliance Manager, Fort Shafter Flats, 1557 Pass Road, Honolulu, Hawaii 96819. Maintain a copy of the appointment orders in the ECO binder.

(2) Attend the Environmental Compliance Officer Certification Course within 60 days of assignment to the ECO position. Maintain a copy of the training certificates in the ECO binder. ECO training certificates from DPW, U.S. Army Garrison, Hawaii and 9th MSC/TSG, Fort Shafter Flats are accepted.

(3) Attend the Environmental Compliance Officer Refresher Course prior to the expiration date on the ECO identification card and maintain a copy of the training certificates on file. ECO training certificates from DPW, U.S. Army Garrison, Hawaii and 9th MSC/TSG, Fort Shafter Flats are accepted.

(4) Provide environmental program oversight and act as the main liaison between the unit within the 9th MSC/TSG Maintenance Facilities and the 9th MSC/TSG Environmental Division.

(5) Submit an ECO/Alternate update memorandum for all ECOs in the 9th MSC/TSG Maintenance Facilities Outside Hawaii (in accordance with Enclosure 2), to the 9th MSC/TSG , Environmental Compliance Manager, Fort Shafter Flats, 1557 Pass Road, Honolulu, Hawaii 96819, fax: [phone]. A copy of this update should be kept in the units ECO binder. (6) Sign a certification statement (Enclosure 3) that they have read and understand this SOP. Provide a copy of these appointment orders to the 9th MSC/TSG, Environmental Compliance Manager, Fort Shafter Flats, 1557 Pass Road, Honolulu, Hawaii 96819, fax: [phone]. Maintain a copy of the appointment orders on file.

(7) Conduct and document weekly Hazardous Waste Shop Storage Point (HWSSP) inspections using the Hazardous Waste Management section of the Environmental Compliance Inspection Checklist (ECIC) (Enclosure 4). Maintain copies of these inspections on-site for a period of 3 years. NOTE: Some of the items in the checklist are locally imposed requirements which exceed federal, state, and Army environmental laws, regulations, and directives.

(8) Conduct and document monthly internal compliance inspections using all applicable sections of the ECIC (Enclosure 4). Failure to meet a minimum of 100% “PASS” on critical ( starred) items and an 85% “PASS” on all other non-critical items on the checklist should be immediately reported to the 9th MSC/TSG, Environmental Division, Environmental Compliance Manager, for assistance in correcting the deficiencies. Maintain copies of these inspections on-site for a period of 3 years. NOTE: Some of the items in the checklist are locally imposed requirements which exceed federal, state, and Army environmental laws, regulations, and directives.

(9) Ensure that hazardous wastes are placed in proper Division of Transportation/Performance Oriented Packaging (DOT/POP) approved containers and sign all HM/HW turn-in/processing documentation.

(10) Coordinate disposal of Hazardous Waste and Non-Regulated Waste with the Environmental Compliance Manager in the 9th Mission Support Command Environmental Division.

(11) Retain on-site for a period of 3 years.

(a) HW Collection Log. (b) Lab Analysis for all unknown contaminated waste containers. (c) MSDSs or HMMS profile for all HW accumulated. (12) Verify waste identification when requested by DRMO-HI.

(13) Ensure that hazard warnings are posted, that containers are properly marked, and that containers are kept closed (bungs or drum rings wrench- tight) except when adding waste.

(14) Ensure that remedial action is initiated for leaks, spills, or improper storage.

(15) Conduct and document quarterly internal training for all employees who handle or come into contact with hazardous materials and hazardous wastes in the following areas, as applicable:

(a) Hazard Communication Program (b) Hazardous Materials Management (c) Hazardous Waste Management (d) Hazardous Waste Minimization (e) Spill Contingency Procedures (f) Aboveground Storage Tanks (g) Underground Storage Tanks (h) Oil/Water Separator

(16) Maintain training logs on file for a period of three years.

(17) Maintain environmental reference publications and regulations on-site or via CD if a generator is available onsite.

(18) Maintain Material Safety Data Sheets at each storage and use location for all HM utilized, stored, received, or shipped, and in each ECO binder.

(19) Obtain and maintain all personal protective equipment (PPE) required IAW MSDSs or Division of Defense (DOD) Hazardous Material Information System (HMIS).

(20) Maintain a copy of the Spill Prevention and Countermeasure Plan on-site, if applicable.

(21) Maintain an inventory of all hazardous materials used/stored and a current diagram of the area(s) these materials are stored (to assist in emergency response).

(22) Each unit will create and maintain an updated HM/HW diagram to be included into this SOP. The Diagram will show the following locations:

(a) Hazardous Material Storage Points (b) Recyclable Material Shop Storage Point (c) Hazardous Waste Shop Storage Point (d) Universal Waste Shop Storage Point

(23) Publicize policies and procedures to ensure an effective, environmentally safe program.

(24) Be present during HW compliance inspections conducted by the United States Environmental Protection Agency (EPA), State of Hawaii Division of Health (DOH), the DPW, Environmental Division, or other regulatory agencies.

(25) Report all spills immediately to the local Spill Responder ______________ and Environmental Division, 808-438-1600x3247.

(26) Ensure that an Authorized Use List (AUL) is submitted to 9th MSC/TSG Environmental Division annually (each fiscal year) for hazardous materials. 5. Definition of Terms. Special terms used in this SOP are explained below:

a. Generator. The unit/activity/person whose act or process produces HW.

b. Hazardous Material (HM). Any material which because of its quantity, concentration, physical, or chemical characteristics may pose a substantial hazard to human health or the environment when transported in commerce, stored, or otherwise managed. HM are normally accompanied by Material Safety Data Sheets (MSDSs).

c. Hazardous Waste (HW). A HW is defined as any waste, be it solid, liquid, or contained gas, which may pose a hazard to human health or may pollute the environment due to its quantity, concentration, or characteristics. A hazardous material becomes a HW when it is no longer useable for its intended purpose and must be discarded. A waste is a hazardous waste if it is listed (see 5.c. (1) below) or meets any of the characteristics described in sections 5.c.(2) - 5.c.(5) below.

(1) Listed Wastes (Toxic and Acute Hazardous Wastes): Known substances which affect the proper functions of a human organism, where prolonged exposure may result in death (e.g., methyl ethyl ketone (MEK), trichlorethylene (TCE), lindane). These wastes are listed at 40 CFR, section 261.31 to 261.33.

(2) Ignitability: A solid waste that is a liquid, having a flashpoint below 140 F as defined in 40 CFR 261.21. A solid waste that is an ignitable compressed gas as defined in 49 CFR 173.300 or an oxidizer as defined in 49 CFR 173.151. Ignitable wastes are assigned the EPA waste code D001 (e.g., waste paint, paint thinner, hydrogen peroxide, etc.).

(3) Corrosivity: Having a pH less than or equal to 2, or greater than or equal to 12.5, as determined by a pH meter. Corrosive wastes are assigned the EPA waste code D002 (e.g., battery acid, caustic cleaners, etc.).

(4) Reactivity: A material that is normally unstable and readily undergoes violent change without detonating, or that reacts violently with water. Reactive wastes are assigned the EPA waste code D003 (e.g., obsolete ammunition, MRE heaters, explosives, etc.).

(5) Toxicity: Extract of the waste fails the Toxic Characteristic Leaching Procedure (TCLP), using specified test methods, that equals or exceeds the concentration of contaminants listed and may release toxic substances or cause a poison hazard to human health or the environment. Toxic wastes are assigned EPA waste codes varying from D004 through D043.

d. Empty Container. A container or inner liner removed from a container that held a HM that is regulated as a HW, or a container or inner liner removed from a container that was used to store a HW is empty if:

(1) All wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container, (e.g., pouring, pumping, aspirating) and no more than 2.5 centimeters (1 inch) of residue remain on the bottom of the container or inner liner.

(2) Pressurized Containers. A pressurized container which has reached atmospheric pressure (i.e., all product under pressure has been expelled) is considered empty and may be disposed of as normal trash.

(3) Listed Toxic and Acute Hazardous Product Containers. A listed toxic and acute hazardous product container (toxic and acute HW, listed at 40 CFR, section 261.31 to 261.33) must either be triple rinsed or crushed and over packed for disposal through the Defense Reutilization and Marketing Office, Hawaii (DRMO-HI). Any rinsate occurring from triple rinsing will also be managed as a HW.

e. Petroleum, Oil, Lubricant (POL) Products. Include, but are not limited to, petroleum based oil, mogas, JP-8, diesel fuel, kerosene, fuel oil, antifreeze, hydraulic fluid (OHA), grease, and (sludge).

f. Satellite Accumulation Point (SAP). Point at or near the point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste. A generator may accumulate as much as 55 gallons of hazardous waste or 1 quart of acutely hazardous waste listed in 40 CFR section 262.34(c)(1).

g. Defense Reutilization and Marketing Office, Hawaii (DRMO-HI). The DRMO-HI accepts hazardous wastes at its storage facility at Pearl Harbor. The DRMO-HI then ships wastes to the appropriate treatment, storage, and disposal facilities (TSDFs).

h. Hazardous Waste Shop Storage Point (HWSSP). The temporary accumulation point for storage of HW and non-hazardous wastes pending disposal through DRMO-HI or other channels.

i. Waste Stream. The process through which the waste is/was generated.

6. Hazardous Material Management.

a. Inventory. Inventories must be current and approved.

(1) Inventory on the 9th MSC/TSG Environmental Division Inventory Form (Enclosure 5) will be submitted to the 9th MSC/TSG Environmental Division, Hazardous Materials Management System Manager before procurement of hazardous materials. No other inventory forms or incomplete inventory forms will not be accepted.

(2) Authorized Use List (AUL) will be generated from the inventory by the 9th MSC/TSG Environmental Division, Hazardous Materials Management System Manager, and issued to the unit POC or ECO.

(3) Hazardous materials procured either by the credit card or SARSS system will be added to the AUL list and approved by the 9th MSC/TSG Environmental Division, Hazardous Materials Management System Manager.

(4) AUL lists must be updated periodically, but at least annually. AUL annual updates must be submitted to the 9th MSC/TSG Environmental Division, Hazardous Materials Management System Manager no later than 30 September of each fiscal year.

(5) Ensure product shelf lives are not expired; have a shelf life extension program in place to revalidate expiration dates.

(6) A Material Safety Data Sheet (MSDS) must be present in a visible and easily accessible location for each hazardous material. A Master MSDS binder must be available in the facility common area or main office via hardcopy for facilities with no generator; or hardcopy, CD, or online for facilities with a generator.

b. Storage: All HM must be properly stored.

(1) Do not store incompatible materials near each other; use MSDSs and compatibility charts to determine which materials may be stored together.

(2) Storage areas shall have secondary containment (i.e., concrete curbs, spill pallets, etc.) to prevent any unplanned or sudden releases into the environment.

(3) Ensure all products are used on a “First-in, First-out” basis.

(4) Ensure new products are segregated from in-use containers.

(5) Ensure that containers are not damaged or leaking.

(6) Ensure products are absolutely required; promptly and properly turn-in excess hazardous materials.

(7) Ensure flammable materials are placed back into flammable storage lockers at the end of each day.

(8) Ensure that materials which are transferred from their original container are transferred to a new container that is capable of safely storing the material (e.g., do not place flammables in plastic containers larger than one pint; use approved metal containers instead).

(9) Ensure that new containers holding transferred materials are properly marked and labeled (i.e., chemical name, manufacturer, national stock number, Mil Spec, etc.).

(10) Required personal protective equipment items shall be available for all hazardous material handlers IAW MSDSs.

7. Hazardous Waste Minimization (HAZMIN).

a. HAZMIN is defined as efforts undertaken during the year to reduce the volume and toxicity of waste generated, and the changes in volume and toxicity of waste actually achieved during the year in comparison with the previous year.

b. HAZMIN methods. There are several methods available to minimize the amount of wastes that are generated.

(1) Inventory control. A majority of the hazardous waste and non-hazardous wastes generated are from unused products. The product is ordered in such quantities that only a portion of the product is used and the remainder is discarded or remains on hand until the shelf life is exceeded. To avoid this condition, utilize inventory control and rotate stock; first in, first out.

(2) Waste segregation. When a waste is generated, segregation of the wastes is required to increase the reclamation potential of the waste material generated. Commingling of waste products can change a minimally regulated recyclable material into a very stringently regulated hazardous waste.

(3) Product substitution. This is an excellent way to reduce hazardous waste by using a less hazardous or sometimes even a non-hazardous product in place of another.

(4) Material handling improvements. Proper handling of hazardous materials and POL products can greatly decrease the amount of hazardous waste generated. Accidents do happen, but storing the HM in the most logical place to minimize the actual handling will reduce the spill or accidental handling possibility.

(5) Recycling. Used oil and oil based products (e.g., diesel, hydraulic and transmission fluid, mogas, etc.) will be placed into drums in the Recyclable Material Shop Storage Point (RMSSP). These products are then picked up by contractors and recycled through an energy recovery process.

8. Typical Waste Streams.

a. Typical waste streams include Recyclable Waste, Universal Waste, Hazardous Waste and Non-Regulated Waste. Typical waste streams from shop maintenance and cleaning are summarized below:

Recyclable Waste: Used vehicle batteries, used oil, used antifreeze, and used fuel are recycled by contractors thru the Environmental Division.
Universal Waste: Batteries, lamps, and pesticides are turned into DRMO thru the Environmental Division.
Hazardous Waste: Solvents, adhesives, paints, degreasers, used dry sweep/absorbents and used oily rags may be hazardous. Contact the Environmental Division for classification and disposal.
Non-regulated Waste: Used oily rags and used dry sweep/absorbents may be Non-regulated waste. Contact the Environmental Division for classification and disposal.

9. Hazardous Communication (HAZCOM)

a. HAZCOM is an OSHA program, and this program is integrated into the 9th MSC/TSG Hazardous Waste Management Plan.

b. HAZCOM requirements are:

i. Identify the hazards. Inventory management is required for all hazardous material in the workplace (Section 6 a (1-3)).

ii. Evaluate the hazards. MSDS are required for all hazardous materials (Section 6 a (6)).

iii. Communication of the hazards.

1. ECOs are trained in evaluating MSDS, and are responsible for communicating the hazards to the units and TPU thru quarterly training (Section 4 b (14)).

2. Labeling and storage is also required for all hazardous material containers (Section 6 b).

iv. Protect the worker from the hazards. ECOs are responsible for maintaining and coordinating with the 9th MSC/TSG Safety office for the procurement, storage, and proper us of PPE for the hazards in the workplace per MSDS evaluation.

10. Hazardous Waste Shop Storage Point Procedures (HWSSP).

a. General. The HWSSP consists of a secure area where all types of waste can be stored properly, AND, is based on the generator status (CESQG or SQG). Flammable cabinets or building with secondary containment will be used for flammable waste. Corrosive cabinets or building with secondary containment will be used for corrosive waste. Secure polypack containers or buildings will be used for toxic waste, non-flammable waste.

b. Hazardous Waste Determination. Before placing any waste in the HWSSP, the ECO must determine what the waste is and whether it is regulated as a hazardous waste. If the waste is a non-regulated, recyclable waste, it should be placed in the Recyclable Material Shop Storage Point (RMSSP). If it is a hazardous waste, place it in the HWSSP. If the waste is an unknown (the user has no reliable knowledge as to how it was generated), a lab analysis must be performed. Using the worst-case scenario, the unknown waste must then be treated as HW and stored in the HWSSP prior to receiving the lab results. Contact the Environmental Division for lab testing, and the Environmental Division will then notify the ECO of the results and a positive identification can be made to characterize the waste.

c. Segregation of wastes. Incompatible wastes should never be stored together (in the same polypack). Improper storage may result in a potentially dangerous chemical reaction. Check compatibility charts to determine whether or not two wastes may be stored together (in the same polypack). Never mix two wastes in one drum. The HWSSP is designed so three different, compatible wastes may be stored together in the polypack.

d. Security. Drum bungs or rings will be wrench tightened and the polypack will be locked at all times when waste is not being added to the drums.

e. Signage. HWSSPs will be identified on the front by a 28” x 35” danger sign reading as follows:

FLAMMABLES
NO SMOKING WITHIN 50 FEET

HAZARDOUS WASTE SHOP STORAGE POINT (HWSSP)
AUTHORIZED PERSONNEL ONLY

IN CASE OF EMERGENCY CONTACT: PRIMARY ECO: ALTERNATE ECO: FIRE DIVISION: MILITARY POLICE: SPILL RESPONDER AT YOUR FACILITY: ___________ ENVIRONMENTAL DIVISION: 808-438-1600X3247/X3246

Point of contact phone numbers will be listed in 1” letters in appropriate spaces. HWSSPs will be identified on all four sides by metal DANGER FLAMMABLES signs. A diagram showing a primary and alternate evacuation route will be posted on or next to the HWSSP.

f. Labeling. The hazardous waste label (red and white sticker) will be placed on each container containing hazardous waste. The label will reflect the name of the waste (e.g., waste fuel, waste paint thinner). The accumulation start date is the date the items were moved into the HWSSP.

g. Accumulation Logs. The Accumulation Logs (Enclosure 6) will be used to document the type and amount of waste added to a drum. One form should be used for each accumulation drum. Place the same number on the log and the drum to avoid confusion on which log corresponds to which drum. One copy of the accumulation log will be kept inside the polypack and one copy will be kept in another readily available location (i.e., an office at the motor pool, etc.). Both copies must be kept current to provide accurate information in the case of emergency. Accurate logs can save time, money, and even lives in the case of an emergency response, as responders will know what hazards they may face in the response operation.

h. Material Safety Data Sheets. One copy of the MSDS or lab analysis for each waste will be kept inside the polypack and one copy will be kept in another readily available location (i.e., an office at the motor pool, etc.).

i. Bonding and Grounding. Flowing liquids can charge drums with static electricity. To prevent fires and explosions that can be caused by this static buildup, the following procedures must be followed:

(1) Drums containing flammable liquids must be properly grounded by connecting the drum and the grounding point with a stranded copper or carbon steel cable.

(2) When transferring flammable liquids between containers (e.g., when pouring waste thinner from a one gallon can to the 15 gallon accumulation drum), the containers must be bonded (connected) together with a stranded copper or carbon steel cable.

(3) There will be no electrical equipment or potentially spark-generating machinery operated within a 50’ radius of the polypack when transferring flammable liquids.

j. Removal of drums. Full 15 gallon drums will be removed from the polypack using a drum sling and forklift.

k. A spill kit and/or supplies must be readily available where HM or HW are stored (Quantities listed in parenthesis are minimums)

(1) Granular absorbent (50 pounds) (2) Absorbent pillows (5) or pads (Bundle of 100) (3) Straight edge, non-sparking shovel or dustpan (1)
(4) Empty over pack drum to accommodate largest storage container (e.g., 30 gallon over pack for 15 gallon accumulation drum) (1) (5) Broom (1) (6) Rubber gloves (2 pair) (7) Rubber apron (2) (8) Rubber boots (2 pair) (9) Goggles (2 pair) (10) Absorbent booms, 8 or 10 feet long (2)

l. Over packing containers of hazardous waste: Over pack the original containers of HW in an approved POP drum rather than transferring the material to an accumulation drum to prevent the possibility of a release of HW to the environment.

11. Satellite Accumulation Point Procedures (SAP).

a. General. The SAP consists of a secure area where hazardous waste can be stored properly at or near the point of generation, and under the control of the operator. Flammable cabinets or building with secondary containment will be used for flammable waste. Corrosive cabinets or building with secondary containment will be used for corrosive waste. Secure polypack containers or buildings will be used for toxic waste, non-flammable waste.

b. Hazardous Waste Determination. Before placing any waste in the SAP, the ECO must determine what the waste is hazardous waste. If the waste is a non-regulated, recyclable waste, it should be placed in the Recyclable Material Shop Storage Point (RMSSP). If the waste is an unknown (the user has no reliable knowledge as to how it was generated), a lab analysis must be performed. Using the worst-case scenario, the unknown waste must then be treated as HW and stored in the HWSSP prior to receiving the lab results. Contact the Environmental Division for lab testing, and the Environmental Division will then notify the ECO of the results and a positive identification can be made to characterize the waste.

c. Segregation of wastes. Incompatible wastes should never be stored together (in the same polypack). Improper storage may result in a potentially dangerous chemical reaction. Check compatibility charts to determine whether or not two wastes may be stored together (in the same polypack). Never mix two wastes in one drum.

d. Security. Drum bungs or rings will be wrench tightened and the polypack will be locked at all times when waste is not being added to the drums.

e. Signage. HWSSPs will be identified on the front by a 28” x 35” danger sign reading as follows:

FLAMMABLES
NO SMOKING WITHIN 50 FEET

SATELLITE ACCUMULATION POINT (SAP)
AUTHORIZED PERSONNEL ONLY

IN CASE OF EMERGENCY CONTACT: PRIMARY ECO: ALTERNATE ECO: FIRE DIVISION: MILITARY POLICE: SPILL RESPONDER AT YOUR FACILITY: _____________ ENVIRONMENTAL DIVISION: 808-438-1600X3247/X3246

Point of contact phone numbers will be listed in 1” letters in appropriate spaces. HWSSPs will be identified on all four sides by metal DANGER FLAMMABLES signs. A diagram showing a primary and alternate evacuation route will be posted on or next to the HWSSP.

f. Labeling. The hazardous waste label (red and white sticker) will be placed on each drum containing hazardous waste. The label will reflect the name of the waste (e.g., waste fuel, waste paint thinner). Do not place the accumulation start date on this label. The accumulation start date should only be filled in when a HWSSP exceeds 55 gallons of HW or 1 quart of acutely HW. DOT hazard labels will be placed on each drum in accordance with the hazard (e.g., Corrosive, Flammable Liquid, Oxidizer, etc.). Each drum will be numbered to correspond with the accumulation log.

g. Accumulation Logs. The Accumulation Logs (Enclosure 6) will be used to document the type and amount of waste added to a drum. One form should be used for each accumulation drum. Place the same number on the log and the drum to avoid confusion on which log corresponds to which drum. One copy of the accumulation log will be kept inside the polypack and one copy will be kept in another readily available location (i.e., an office at the motor pool, etc.). Both copies must be kept current to provide accurate information in the case of emergency. Accurate logs can save time, money, and even lives in the case of an emergency response, as responders will know what hazards they may face in the response operation.

h. Material Safety Data Sheets. One copy of the MSDS or lab analysis for each waste will be kept inside the polypack and one copy will be kept in another readily available location (i.e., an office at the motor pool, etc.).

i. Bonding and Grounding. Flowing liquids can charge drums with static electricity. To prevent fires and explosions that can be caused by this static buildup, the following procedures must be followed:

(1) Drums containing flammable liquids must be properly grounded by connecting the drum and the grounding point with a stranded copper or carbon steel cable.

(2) When transferring flammable liquids between containers (e.g., when pouring waste thinner from a one gallon can to the 15 gallon accumulation drum), the containers must be bonded (connected) together with a stranded copper or carbon steel cable.

(3) There will be no electrical equipment or potentially spark-generating machinery operated within a 50’ radius of the polypack when transferring flammable liquids.

j. Removal of drums. Upon accumulation of 55 gallons and an ASD on the label, the ECO has three days to move the drums out of the SAP and into the HWSSP.

k. A spill kit and/or supplies must be readily available where HM or HW are stored (Quantities listed in parenthesis are minimums)

(1) Granular absorbent (50 pounds) (2) Absorbent pillows (5) or pads (Bundle of 100) (3) Straight edge, non-sparking shovel or dustpan (1)
(4) Empty over pack drum to accommodate largest storage container (e.g., 30 gallon over pack for 15 gallon accumulation drum) (1) (5) Broom (1) (6) Rubber gloves (2 pair) (7) Rubber apron (2) (8) Rubber boots (2 pair) (9) Goggles (2 pair) (10) Absorbent booms, 8 or 10 feet long (2)

m. Over packing containers of hazardous waste: Over pack the original containers of HW in an approved POP drum rather than transferring the material to an accumulation drum to prevent the possibility of a release of HW to the environment.

12. Recyclable Material Shop Storage Point (RMSSP) Procedures.

a. General. The RMSSP is used for the accumulation of recyclable materials (e.g., used oil, transmission or power steering fluid, diesel, synthetic oil, antifreeze, gasoline) and storage of Non-Regulated wastes. Recyclable materials will be stored at the RMSSP in DOT/POP approved 55 gallon steel drums.

b. Segregation of recyclables. Never mix recyclable materials in the same drum. Mixing recyclable materials may contaminate the whole drum, requiring further laboratory testing prior to disposal. Testing one drum usually costs around $1000.00. Incompatible recyclables should never be stored together. Improper storage may result in a potentially dangerous chemical reaction. Check the compatibility chart to determine whether or not two recyclable materials may be stored together. Incompatible recyclable materials should never be stored where they share the same secondary containment, as in the rare case that both containers leaked, a reaction could occur.

c. Security. Drum bungs or rings will be wrench tightened and the RMSSP will be locked at all times when recyclable material is not being added to the drums.

d. Signage. RMSSPs will be identified on the front by a 28” x 35” danger sign reading as follows:

FLAMMABLES
NO SMOKING WITHIN 50 FEET

RECYCLABLE MATERIAL
SHOP STORAGE POINT (RMSSP)
AUTHORIZED PERSONNEL ONLY

IN CASE OF EMERGENCY CONTACT: PRIMARY ECO: ALTERNATE ECO: FIRE DIVISION: MILITARY POLICE: SPILL RESPONDER AT YOUR FACILITY: ___________ ENVIRONMENTAL DIVISION: 808-438-1600X3247/X3246

Point of contact phone numbers will be listed in 1” letters in appropriate spaces. RMSSPs will be identified on all four sides by metal DANGER FLAMMABLES signs. A diagram showing a primary and alternate evacuation route will be posted on or next to the RMSSP.

e. Labeling. Drums will be labeled appropriately as stated below:

2” LETTERING
USED OIL ONLY
ASBESTOS-DANGER INHALATION HAZARD
USED ANTIFREEZE ONLY
USED JP-8/DIESEL ONLY
USED OIL (SYNTHETIC OIL)

The label will reflect the name of the recyclable material (e.g., used oil, used antifreeze, etc.). Drums containing materials meeting the definition of any of the DOT hazard classes will be labeled with the appropriate DOT hazard label (e.g., MOGAS will be labeled with the “Flammable Liquid” label). Consult MSDSs to determine whether materials meet the definition of any of the hazard classes. All drums will be numbered to correspond with the accumulation log.

f. Accumulation Logs. The Accumulation Logs (Enclosure 6) will be used to document the type and amount of recyclable material added to a drum in the RMSSP. One form should be used for each accumulation drum. Place the same number on the log and the drum to avoid confusion on which log corresponds to which drum. One copy of the accumulation log will be kept inside the RMSSP and one copy will be kept in another readily available location (i.e., an office at the motor pool, etc.). Both copies must be kept current to provide accurate information in the case of emergency. Accurate logs can save time, money, and even lives in the case of an emergency response, as responders will know what hazards they may face in the response operation.

g. Material Safety Data Sheets. One copy of the MSDS for each recyclable waste will be kept inside the RMSSP and one copy will be kept in another readily available location (i.e., an office at the motor pool, etc.).

h. Bonding and Grounding. Flowing liquids can charge drums with static electricity. To prevent fires and explosions that can be caused by this static buildup, the following procedures must be followed:

(1) Drums containing flammable liquids must be properly grounded by connecting the drum and the grounding point with a stranded copper or carbon steel cable.

(2) When transferring flammable liquids between containers (e.g., when pouring waste thinner from a one gallon can to the 55 gallon accumulation drum), the containers must be bonded (connected) together with a stranded copper or carbon steel cable. (3) There will be no electrical equipment or potentially spark-generating machinery operated within a 50’ radius of the polypack when transferring flammable liquids.

i. Turn-in of Recyclable Materials. A scheduled pick up of recyclable materials must be performed by a contractor approved by the Environmental Division. Drums may be re-used for accumulation of the same recyclable material.

j. Turn-in of Non-Regulated Waste (used dry sweep/used rags). Used dry sweep and used rags accumulated from maintenance on service machinery will be turned-in to a contractor approved by the Environmental Division IAW the following procedures:

(1) Prior to transfer, place used rags/absorbent pads in 10 gallon clear plastic bags and store the bags in a closed metal container.

(2) Used dry sweep must be stored in closed, open head metal drums.

(3) Used dry sweep and used rags/pads must not be beyond saturation to the point that there is free-flowing liquid in the bag. Saturated rags must be managed separately.

(4) Affix non-regulated waste label on drum and mark the label with the words “USED DRY SWEEP” or “USED RAGS/PADS”.

k. A spill kit and/or supplies must be readily available where HM or HW are stored (Quantities listed in parenthesis are minimums)

(1) Granular absorbent in new dry-sweep container with lid (50 pounds) (2) Absorbent pillows (5) or pads (Bundle of 100) (3) Straight edge, non-sparking shovel or dustpan (1) (4) Broom (1) (5) Used dry sweep container with lid (1) (6) Rubber gloves (2 pair) (7) Rubber boots (2 pair) (8) Absorbent booms, 8 or 10 feet long (2) (9) Drum puncture repair paste (1 can/tube) (10) Empty over pack drum to accommodate largest storage container (e.g., 85 or 95 gallon over pack for 55 gallon accumulation drum) (1)

13. Lead Acid Battery Room

a. General. The Lead Acid Battery room is used for the accumulation of lead acid batteries and corrosive battery acid. A corrosive locker is required for acids with a pH less than or equal to 2 OR a pH greater than or less than 12.5.

b. Segregation. Clearly separate the new batteries from the used batteries.

c. Security. No special requirements.

d. Signage. Battery rooms will be identified on the front by a 28” x 35” danger sign reading as follows:

CORROSIVE-ACIDS

BATTERY ROOM

Point of contact phone numbers will be listed in 1” letters in appropriate spaces.

e. Labeling. Label each new battery “New” and each used battery “Used Battery”. For the State of Hawaii, used batteries must be labeled “Used Battery, Out of Service Date”. For example, a used battery that expired on 1 January 2011 must be labeled: “Used Battery, 1 Jan 2011”.

f. Accumulation Logs. For the State of Hawaii, the Universal Lead Acid Log will be used for the as documentation of Universal Waste. One copy of the accumulation log will be kept inside the Battery Room and one copy will be kept in another readily available location (i.e., an office at the motor pool, etc.).

g. Material Safety Data Sheets. One copy of the MSDS for each battery acid waste be kept inside the Battery Room and one copy will be kept in another readily available location (i.e., an office at the motor pool, etc.).

h. Turn-in of Lead Acid Batteries. A scheduled pick up of batteries must be performed by a contractor approved by the Environmental Division.

i. A spill kit and/or supplies must be readily available where HM or HW are stored (Quantities listed in parenthesis are minimums)

(1) Acid spill absorbent in new dry-sweep container with lid (10-25 pounds) (2) Acid absorbent pads (10-25)

14. Transfer of HW for Disposal.

a. When the 9th MSC/TSG Maintenance Facilities Outside Hawaii has accumulated 55 gallons of hazardous waste of one quart of acutely hazardous waste, contact the Environmental Division for coordination with DRMO or approved contractors.

b. Prior to transferring wastes, the ECO will:

(1) Inspect Container(s):

(a) Ensure that containers used for transporting HW and non-hazardous wastes are in good condition. If containers are not acceptable, the 9th MSC/TSG Environmental Division will assist the ECO to over pack the container into the next larger size.

(b) Ensure that the container being used will not react with and is compatible with the HW being stored. If containers are not compatible with wastes being disposed of, the 9th MSC/TSG Environmental Division will assist the ECO to repackage wastes into containers compatible with the wastes.

(c) Ensure containers holding HW are always closed during transportation/storage and handled in a manner which will not cause the container to rupture or leak.

(d) Ensure containers holding HW are labeled/marked describing the contents (i.e., waste solvent, waste paint etc.) and with the words “HAZARDOUS WASTE”.

(e) Provide the Environmental Division, Environmental Compliance Manager the most HW inventory and current MSDS.

(f) Ensure that one (1) copy of the Accumulation Log is completed and kept in the ECO binder.

(g) In cases where the HW accumulated at the Hazardous Waste Shop Storage Point (HWSSP) is in excess of the 55 gallon hazardous waste/one quart acutely hazardous waste allowable limit, the generator will immediately annotate the date that the limit was exceeded as the Accumulation Start Date on the HW label.

c. Coordinating with DRMO and waste disposal:

(1) For Hawaii Facilities, the Compliance Manager coordinates with DRMO:

(a) Review and complete all required documentation with DRMO or the approved contractor prior to transfer.

(b) Ensure that copies of the Hazardous Waste Profile Sheet (HWPS-DRMS Form 1930) and DA Form 1348 are completed in accordance with DRMO-HI guidance and federal and state regulatory requirements.

(c) Lab analysis when specific generator knowledge and exact waste stream generation is identified by the ECO. The 9th MSC/TSG Environmental Division will ensure that MSDSs reflect contents of containers.

(e) Laboratory analysis is required if generator knowledge of the exact waste stream is not known (see paragraph 8.b.). However, see paragraph 10.c. for instances where the generator’s 3 day transfer period is ready to expire.

(f) HW will only be accepted when generated from activities within the 9th MSC/TSG Maintenance Facilities in Hawaii.

(g) Submit DRMO requests for pickup using the appropriate Contract Line Item Number (CLIN) per contract for the facility.

(h) Maintain the 80 hour, 49 CFR DOT course certification.

(i) Sign manifests.

(j) Maintain copies of manifests.

(k) Ensure that manifest signatures are returned to the generator within the 60 day time frame.

(1) For Facilities OUTSIDE Hawaii, the ECO coordinates with DRMO and/or approved contractors:

(a) Review and complete all required documentation with DRMO or the approved contractor prior to transfer. The approved contractor must be approved by the Environmental Division.

(b) Ensure that copies of the Hazardous Waste Profile Sheet (HWPS-DRMS Form 1930) and DA Form 1348 are completed in accordance with DRMO guidance and federal and state regulatory requirements.

(c) Lab analysis must be requested thru the Environmental Division.

(f) HW will only be accepted when generated from activities within the 9th MSC/TSG Maintenance Facilities.

(g) Submit DRMO requests for pickup using the appropriate Contract Line Item Number (CLIN) per contract for the facility.

(h) Maintain the 80 hour, 49 CFR DOT course certification.

(ii) Sign manifests.

(j) Maintain copies of manifests.

(k) Ensure that manifest signatures are returned to the generator within the 60 day time frame.

The Environmental Division will review or assist the facilities outside of Hawaii upon request.

f. Hazardous Wastes found on Army Installations/Training Areas.

(1) Hazardous Wastes from unknown sources shall not be transported to the HWSSP without approval from the 9th MSC/TSG, Environmental Division. The unit/activity discovering the containers will immediately contact the 9th MSC/TSG Environmental Division for specific instructions.

(2) Any questions on unknowns should be directed to the 9th MSC/TSG, Environmental Division, 808-438-1600x3247.

15. Universal Waste Management

a. General. Examples of Universal Waste generated at 9th MSC/TSG Maintenance Facilities include Universal Waste Batteries and Universal Waste Lamps.

(1) Lithium batteries. Lithium batteries will be turned into DRMO and managed as UW IAW 40 CFR 273 and HAR 11-273. The generator will not activate the complete discharge device (CDD). The ECO will ensure that CDD and exposed terminals be protected and taped. The batteries will be placed in a plastic bag-lined box. The ECO will provide an itemized list of the amount and type of batteries (i.e. BA 5590, BA 5800) and a statement certifying that the lithium batteries are of the balanced type (see section 5.8(e)(1)) to the Environmental Division upon pre-inspection of the waste prior to pickup. Lithium batteries that do not qualify under the universal requirements (i.e. cracked, leaking) will be managed and disposed of as Hazardous Waste. Unbalanced Lithium batteries (contains 4.2g of lithium to 24.5g of sulfur dioxide) will be managed IAW 5.8(d). In an unbalanced battery lithium metal can react with the electrolyte in the absence of sulfur dioxide to produce Lithium cyanide (toxic), lithium hydroxide (corrosive), heat and methane (flammable) which may cause rupturing. DRMO will not accept physical custody. The UW generator must contain any UW battery in a container which must be closed, structurally sound, compatible with the contents of the battery, and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. Any battery that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions in a container must be managed and disposed as HW.

(2) Universal Waste Lamps. Lamps will be turned into DRMO and managed as UW IAW 40 CFR 273 and HAR 11-273. If a lamp is changed by the unit, the ECO must manage lamps in a way that prevents releases of any UW or component of a UW to the environment, as follows:

a. The ECO must contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. Such containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions.

b. The ECO must immediately clean up and place in a container any lamp that is broken and any lamp that shows evidence of breakage, leakage, or damage that could cause the release of mercury or other hazardous constituents to the environment. Containers must be closed, structurally sound, compatible with the contents of the lamps and must lack evidence of leakage, spillage or damage that could cause leakage or releases of mercury or other hazardous constituents to the environment under reasonably foreseeable conditions.

b. Labeling/Marking.

(1) The ECO must label or mark the UW to identify the type of UW as specified below:

a. UW batteries (i.e., each battery), or a container or tank in which the batteries are contained, must be labeled or marked clearly with the following phrases: ``Universal Waste-Battery(ies) ' ' .

b. UW Lamps: Each lamp or a container or package in which such lamps are contained must be labeled or marked clearly with the following phrase: ``Universal Waste-Lamp(s) ' '. (2) The Accumulation Start Date (ASD) must be annotated on the container when the first quantity of waste is generated (the date the item was taken out of service) for that specific container.

c. Accumulation Time Limits

(1) The UW Logs (Enclosure 7) will be used to document the type and amount of universal material added to a drum in the RMSSP. One form should be used for each accumulation drum. Place the same number on the log and the drum to avoid confusion on which log corresponds to which drum. One copy of the accumulation log will be kept inside the RMSSP and one copy will be kept in another readily available location (i.e., an office at the motor pool, etc.). Both copies must be kept current to provide accurate information in the case of emergency. Accurate logs can save time, money, and even lives in the case of an emergency response, as responders will know what hazards they may face in the response operation.

(2) The UW Logs for Lead Acid Batteries (LAB) (Enclosure 8) is for the State of Hawaii ONLY; and must be managed according to the above paragraph (Section 15 c (1)).

(3) The units/activities who generate UW must turn-in the waste within 6 month of the Accumulation Start Date (ASD).

(3) For UW Lamps the units/activities can accumulate no more than 150 of any type of spent lamps or for no more than 6 months from the ASD.

(4) DRMO may accumulate UW for no longer than one year from the date (ASD) the UW is generated.

16. Spill Response.

a. Personnel will take immediate personnel protective measures. Within 5 minutes thereof, notify the Environmental Division at 808-438-1600x3247 and the EOC at 808-438-1600x3330. This number will be posted on a bulletin board in the work areas were hazardous materials/waste are stored.

b. The unit will designate a spill response coordinator and an alternate (usually the ECOs) that will be responsible for spill response and reporting. The spill response coordinators will be identified to all personnel in the work area and on bulletin boards.

c. POCs for assistance within the 9th MSC/TSG Environmental Division are listed below.

Title Phone #

Chief, Environmental Division 808-438-1600x3247 Environmental Compliance Manager 808-438-1600x3246 HMMS/Recycling Manager 808-438-1600x3307 EMS Manager 808-438-1600x3533

d. Initial Spill Response Actions. The following initial defensive actions shall be implemented as necessary upon discovery of a spill:

(1) Evacuate the area of non-essential personnel and direct personnel to notify Environmental Division, the Military Police, and Fire Department.

(2) Summon emergency medical services if personnel are injured.

(3) Remove ignition sources (cigarettes, torches, etc.) and turn off electric power in the case of a flammable spill to minimize fire hazards.

(4) Ventilate the area in the case of the presence of volatile materials or dense vapors spilled inside a building.

(5) Stop flow of material, if it is safe to do so, by plugging the leak, activating any emergency shut offs, reorienting the container, placing the container in a drip pan, placing the container in an over-pack container, or using any other expedient method available.

(6) Contain spilled material to keep spill from spreading and flowing beyond the immediate area or into drains, by using plugs, mats, absorbents, spill booms, or any other expedient method available.

(7) As the spill area is isolated, the “hot zone” should be expanded in a DOWNWIND DIRECTION, paying particular attention to sensitive populations (e.g. schools, child-care center, medical facilities, etc.) if spilled materials are volatile, or there is a short-term danger if material is inhaled.
e. Initial Notification Procedures. The person discovering the spill shall fill out the Spill Report form (Enclosure 10) and report it immediately to the organization’s designated spill response coordinator, who will immediately notify 9th MSC/TSG Environmental Division.
The Military Police and/or the Fire Department shall be contacted 1) if there is a threat of fire, 2) danger to public health, or 3) it could affect a sensitive environmental area (such as entering a water body). All spills shall be immediately reported to 9th MSC/TSG Environmental Division by the organization spill response coordinator, Military Police, Fire Department or anyone with knowledge of a spill.

f. The unit/activity will identify a POC to represent them at the quarterly Environmental Quality Control Committee meeting. The POC will explain what corrective actions have been taken to insure the spill does not recur.

17. Inspection and Corrective Action

a. ECOs must perform monthly inspections using the Environmental Compliance Inspection Checklist (ECIC) (Enclosure 4).

b. ECOs must perform weekly inspections using the ECIC, Section C for HWSSP and SAP areas.

c. ECOs must correct all deficiencies noted in the internal inspection “on the spot”.

d. Quarterly or annual inspections are performed by 9th MSC/TSG Environmental Division Compliance Manager.

e. ECOs must correct all deficiencies noted in the 9th MSC/TSG inspection using the Continuous Improvement Form (Enclosure 9).

f. External inspections can occur at any time. ECOs must report external inspections and inspection documents to the 9th MSC/TSG Environmental Division Compliance Manager.

g. ECOs must correct all deficiencies noted in the external inspections in the format as specified by the Organization inspecting.

18. SOP Modifications. This SOP is the standard generic procedures for all 9th MSC/TSG facilities. Each facility must insert specific modifications to the SOP sections 8, 14, 15 and 16 as needed in paragraph 19, and submit the final draft to Tammy Collins, [e-mail].

19. SOP Modification for Fort Shafter Flats, Operational Maintenance Support (OMS), Building 1575.

a. Section 8, Typical Waste Streams. No Change Required.

b. Section 14, Transfer of HW for Disposal. The ECO for each unit within the OMS is responsible to manage unit inventory, request shelf life extensions, and turn in HW inventories and MSDS to Tammy Collins for review and DRMO submission. c. Section 15, Universal Waste Management. The approved contractor for UW pickup is Interstate Battery.

d. Section 16, Spill Response. No Change Required.

20. Point of Contact. Questions regarding the procedures in this SOP should be directed to Environmental Division Chief, Wayne Mitsko at 808-438-1600x3247 and the Primary ECOs: SFC Bryant Matsumoto, 740th; SSG Iapesa Fanolua, 411th, and Bernabe Rafanan, 322nd.

SFC Bryant Matsumoto
Facility Manager

Enclosures:
1- ECO Appointment Order Template
2- ECO Monthly Update Memo Template
3- SOP Certification Template
4- ECIC
5- Inventory Forms
6- Accumulation Log
7- Universal Waste (UW) Log
8- Universal Waste (UW) Log for Lead Acid Batteries (LAB)
9- Continuous Improvement Form
10- Spill Form

References: k. Chemistry of Hazardous Materials, Eugene Meyer, Prentice-Hall, Inc., 1990.