G: Manual 006 Waste Annx

G: Manual 006 Waste Annx

1 October 2001ORARNG Pam 200-1

Annex H

HAZARDOUS MATERIAL MANAGEMENT

1. Requirement Reference: AR 200-1, Chapter 4

ORARNG Pam 200-1, Chapter 7

  1. Affected Units and Activities: Units and activities that use or store hazardous materials

or regulated wastes, as listed below:

a. Inventory of Hazardous MaterialAll ORARNG units and facilities

  1. Above-Ground Storage Tanks
  • AASF #1 2 x 12,000 gal JP8, 350 gal used oil
  • AASF #22 x 12,000 gal JP8, 500 gal used oil
  • COUTES12,000 gal JP8, 500 gal used oil
  • Camp Withycombe12,000 gal JP8, 2 x 350 gal used oil
  • La Grande OMS3,000 gal JP8, 250 gal used oil
  • Pendleton Armory3,000 gal JP8
  • Lebanon OMS350 gal used oil
  • Medford OMS500 gal used oil
  • Kliever OMS350 gal used oil
  • Salem OMS350 gal used oil
  • Tigard OMS350 gal used oil
  • Cp Rilea 7,000 gal JP8, 6,000 gal JP8, 2 x 1,000 gal gasoline, 500 gal used oil
  1. Propane Tanks
  • Burns Armory1,000 gal
  • Coos Bay Armory2 x 500 gal
  • Grants Pass Armory2,000 gal
  • La Grande OMS1,000 gal
  • COUTES4 x 1,000 gal, 1,500-gal
  • La Grande OMSS - UCD2 x 1,000 gal, 500 gal

c. Heating Oil Underground Storage Tank Inventory

  • Coos Bay Armory 5,000 gal
  • Mc Minnville Armory10,000 gal
  • Hood River (tin shed) 750 gal
  • Redmond Armory 1,750 gal

d. Fluorescent Light Ballast InventoryAny facility with an inventory verifying the presence of ballasts containing PCBs, or any facility with ballasts suspected of containing PCBs

3. Implementation:

a. HM INVENTORIES AND MSDS

(1)Unit EPOC must:

(a) Maintain an inventory of unit HM (AGO Form 200-1-3).

(b)Maintain an MSDS for each of the HM on the inventory list.

(c)Notify users of the building if they can unreasonably come in contact with a HM and notice per HAZCOM is required.

(d)Obtain approval from USPFO-L or AGI-ENV to local-purchase any HM that has not been previously approved.

(e)Keep on hand only a sufficient amount of any HM required to maintain operations and not stockpiling more than what is reasonably necessary.

(2)SMW must:

(a)Maintain an inventory of HM used in facility maintenance (AGO Form 200-1-3).

(b)Maintain an MSDS for each HM on the inventory list.

(c)Notify users of the building if their activities could expose them to HM (notice required by HAZCOM Program).

(d)Obtain approval from AGI-O to local-purchase HM through the work order system. AGI-O will coordinate with AGI-ENV, as required.

(e)Keep on hand only a sufficient amount of any HM required to maintain operations and not stockpiling more than what is reasonably necessary.

(3)Facility EPOC must ensure Unit EPOC(s) and SMW complete above requirements, and act as the point of contact for regulatory agency inspections, site visits, or written inquiries.

b. STORAGE TANKS

(1) Above-ground mobility fuel storage tanks: Pendleton is the only armory where an AST has been installed to store mobility fuel. All other ASTs are located at training sites, logistics facilities, or maintenance facilities (noted above). Tanks are installed for the purpose of supporting unit missions. Managing these assets is a unit function assigned to the Unit EPOC, with oversight by the Facility EPOC. Tasks require monitoring fuel deliveries and dispensing of fuel, inspecting and discharging precipitation from secondary containment structures, and documenting inspections/discharges on AGO Form 200-1-8. There is no SMW requirement.

(2) Above-ground heating oil or propane tanks: There are no above-ground heating oil tanks, so there is no requirement. Propane tanks support the facility, so managing them is an SMW responsibility. There should be no unit or facility EPOC requirement.

(3) Above-ground fuel tanks for facility maintenance: Fuel for facilities maintenance operations is maintained in dedicated tanks at Camp Rilea and Camp Withycombe. These tanks are the responsibility of the SMW (supervisor of the state crew). Inspections must be documented on AGO Form 200-1-5. There are no unit or facility requirements for these tanks.

(4) Above-ground used oil storage tanks. Used oil is accumulated and temporarily stored at maintenance facilities throughout the state prior to processing for disposal. These tanks range in size from 350 to 500 gallons. The Unit EPOC is responsible for managing, inspecting, and documenting inspections for these tanks on AGO Form 200-1-5. There is no Facility EPOC or SWM requirement for these tanks.

(5) Underground heating oil tanks. Heating oil tanks are part of the facility and are a SMW responsibility. The SMW should monitor fuel levels, document monthly inventory, order fuel and observe fuel deliveries, and forward problems or concerns to AGI-O on AGO Form 200-1-4. There is no Unit EPOC requirement in managing heating oil tanks. There is no Facility EPOC requirement in managing heating oil tanks unless no SMW is assigned to the facility. If this is the case, the Facility EPOC must complete tasks normally assigned to the SMW.

c. PCBS IN FLUORESCENT LIGHT BALLASTS

(1) Fluorescent lights are part of the facility, so the ballasts are a SMW responsibility. The SMW must know the location of all suspect ballasts. When ballasts fail and are replaced by a certified electrician, policy should be that the electrician disposes of the waste ballast(s). If that cannot be done, the SMW will secure waste ballasts and turn them in IAW guidance to the Supply Sergeant for disposal through the supporting OMS.

(2) The Unit EPOC and Facility EPOC should be aware of fluorescent light ballast locations so appropriate precautions can be taken in the event of a failure or other emergency during the absence of the SMW.

4. Requirement Summary:

a. Inventory of Hazardous Material. An annual inventory of hazardous material and regulated wastes must be submitted to allow AGI-ENV to prepare appropriate EPCRA reports. The unit or activity will also use the inventory to assist in managing the quantity and types of hazardous materials stored and used at the site, and to ensure that appropriate Material Safety Data Sheets are available. This list is similar to that required by SAO-S for compliance with the Hazard Communication Standard (see ORARNG Pam 385-10), but information is used to comply with different regulatory requirements. The primary responsibility for ensuring that a HM inventory is maintained rests with the EPOC. However, separate inventories may be maintained by the EPOC and the AOT, provided all HM is identified and inventoried. Inventories are to be maintained on AGO Form 200-1-3, found at the end of Chapter 7, ORARNG Pam 200-1.

b. Above-Ground Storage Tank Management. Above-ground storage tanks must be installed under permits issued by the State Fire Marshal. AGI-ENV, AGI-O, or AGI-C will obtain required permits, depending upon how procurement of the tank is funded. A copy of the permit will be available from AGI-ENV and should be maintained at the facility. No operating permits from DEQ or other regulatory authority are required. However, in order to meet spill prevention control and countermeasure requirements, above-ground tanks must be routinely inspected to ensure they are in good condition and not leaking. Inspections must also document that spills during refueling operations have not occurred or are cleaned up immediately. In addition to any requirements defined in an applicable Integrated Contingency Plan for the facility, monthly inspections by the EPOC are required by ORARNG policy and must be documented on AGO Form 200-1-5, found at the end of Chapter 7 of this pamphlet. All parts of the tank system must be carefully inspected to ensure good condition of materials and working order of systems.

c. Heating Oil Underground Storage Tank Inventory. Monitoring of heating oil stored in USTs is difficult but is required to ensure suspected leaks are identified and, when found, are properly reported. All ORARNG heating oil USTs are more than 20 years old, the expected life of such tanks. ORARNG policy is to convert facilities to other fuel sources as soon as possible, but risk management in the interim is necessary. Therefore, the designated SMW must take reasonable precautions to ensure leaks are detected quickly and reported properly. AGI-O, in coordination with AGI-ENV, will ensure sites are cleaned up IAW regulatory requirements. The area around the fill port should be inspected by the SMW after each fuel delivery to ensure no spills occurred during the transfer. Monthly fuel inventories by the SMW are required on AGO Form 200-1-4, found at the end of Chapter 7 of this pamphlet.

  1. Fluorescent Light Ballast Inventory. Older fluorescent light ballasts and electrical transformers may contain a liquid substance known as polychlorinated biphenyl (PCB). Management and disposal of items containing PCB are regulated by both federal and state law. All ORARNG transformers have been inspected and are PCB-free, so the primary concern is fluorescent light ballasts. A current inventory of ballasts containing PCBs, maintained by the applicable SMW, is encouraged to ensure that:

(1)Facility personnel know where ballasts containing PCB are located.

(2)Spills or leaks caused by ballast failure are properly cleaned up and reported. Appropriate procedures and use of PPE during cleanup operations are required.

(3)Disposal of contaminated ballasts is accomplished IAW regulatory requirements. If not marked "Non-PCB", ballasts must be handled and disposed of as though they contain this regulated material. There is no prescribed format for a PCB ballast inventory.

In the absence of a ballast inventory, the SMW must monitor ballast failure and removal to determine disposal requirements in accordance with regulatory requirements.

  1. Submittal Requirements: Once completed, file the following original forms at this annex. Submit copies through command channels to AGI-ENV, only as requested in the future. Alternate forms are acceptable, if approved by AGI-ENV and provide the same information.

a. Inventory of Hazardous MaterialsAnnual Inventory to AGI-ENV on AGO Form 200-1-3 (supersedes all others)

b. Above-Ground Storage TanksMonthly Inspection on AGO Form 200-1-5

c. Heating Oil UST InventoryMonthly Inventory on AGO Form 200-1-4

d. Fluorescent Light Ballast InventoryNone required -file information, if available

6. Documentation Requirements:

  1. Maintain a copy of the most recently completed AGO Form 200-1-3, Hazardous Substance Inventory, to accurately list current HM on hand at this annex (EPOC and/or SMW).
  1. Maintain a copy of Above-ground Storage Tank permit(s) for the facility, if applicable, at this annex (Unit EPOC). Copies of permits will be provided by AGI-ENV.
  1. Maintain a current inventory of heating oil stored in an underground tank on AGO Form 200-1-4, Heating Oil Storage Tank Monthly Inventory, at this annex (SMW).
  1. Maintain a current record of Above Ground Storage Tank inspections on AGO Form 200-1-5 at this annex (Unit EPOC).
  1. Maintain a current inventory of, or otherwise monitor use and disposal of, fluorescent light ballasts that contain (or may contain) PCBs for the facility at this annex (SMW). If an inventory is conducted, any inventory format is authorized as long as it identifies the location and number of ballasts to be monitored.
  1. Maintain a current record of water discharges from AST secondary containment structures on AGO Form 200-1-8 at this annex.

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