1 October 2001 ORARNG Pam 200-1
Chapter 8
HAZARDOUS WASTE MANAGEMENT
8-1. REFERENCES
a. AR 200-1, Chapter 5
b. AR 420-47, Solid and Hazardous Waste Management
c. 40 CFR parts 260-299
d. Oregon Revised Statutes (ORS) Chapter 465 and 466
e. Oregon Administrative Rules (OAR) Chapter 340, Div 100-110
f. ORARNGR 420-47, Hazardous Material and Waste Management Plan
8-2. SCOPE
a. This chapter defines ORARNG policies and procedures for managing wastes defined by regulations as “hazardous” and are controlled by current regulations. It also addresses other wastes that must be specially handled in order to protect the environment. Since all activities generate some type of wastes during operations, requirements apply to all units and facilities. Requirements are intended to protect public health and the environment, conserve valuable material and energy resources, and comply with the law. The ORARNG will:
(1) Ensure compliance with federal, state, and local requirements.
(2) Specify waste management practices, including the generation, treatment, storage, disposal, and transportation of wastes to protect public health and the environment and comply with applicable regulations.
(3) Reduce the need for corrective action through management of regulated wastes.
(4) Minimize the volume and toxicity of generated wastes using economically practicable methods that emphasize pollution prevention, source reduction, material recycling, and material reuse.
b. This chapter also identifies requirements and implementing actions necessary to meet Department of Army goals for hazardous waste minimization (HAZMIN). However, pertinent parts of the HAZMIN program that relate to recycling are addressed in Chapter 10 and pollution prevention initiatives are addressed in Chapter 9 of this pamphlet.
8-3. BACKGROUND INFORMATION
a. The ORARNG uses many items that can contaminate the environment if improperly managed. The ORARNG goal is to define requirements necessary to manage hazardous wastes in order to comply with applicable Federal, State and Army regulations. Other wastes requiring special handling are also addressed. Non-hazardous solid wastes are addressed in Chapter 10 of this pamphlet. Questions on management and disposal of medical and/or radiological wastes must be directed to the Occupational Health Nurse (ARP-OH) or the State Safety Manager (SAO-S).
b. Regulations controlling hazardous waste management are numerous, detailed, challenging, and constantly changing. Since every ORARNG facility and unit generates some type of regulated wastes, an in-depth program is required to ensure all requirements are identified and implemented.
c. Subtitle C of the Resource Conservation and Recovery Act (RCRA-C) provides requirements and standards for generating, transporting, treating, storing, and disposing of hazardous, universal, and many special wastes. In order to meet these requirements, ORARNG guidance includes:
(1) Responsibilities of organizations and personnel in generating, accumulating, transporting, and disposing of regulated wastes.
(2) Procedures for every ORARNG facility that generates, transports, and disposes of regulated wastes.
(3) Record-keeping and training requirements to describe management activities undertaken at each facility to comply with federal, state, and local requirements.
d. Applicable Army Hazardous Waste Minimization (HAZMIN) goals, which are herewith adopted by the ORARNG, are to:
(1) Achieve a 50 percent reduction in the quantity of hazardous waste generated in future calendar years when compared to a baseline calendar year of 1994.
(2) Incorporate HAZMIN considerations and techniques into the overall life cycle of present and future hazardous materials use. This includes the design, development, and maintenance of new and existing weapons systems and the costs of waste disposal.
(3) Institute “front end” reduction of hazardous waste generation and disposal by using methods such as, but not limited to, hazardous materials substitution, closed loop recycling, process changes, proper waste identification, delisting, and waste segregation.
e. The generation of hazardous waste by the ORARNG results in both short and long term liability in terms of management requirements, disposal costs, environmental damage, and mission performance distracters. As a result, ORARNG has adopted a policy of reducing the volume and toxicity of wastes generated by ORARNG activities to the greatest degree possible.
8-4. ENVIRONMENTAL COMPLIANCE STATEMENT
a. All ORARNG units and activities that generate hazardous, universal, or special wastes must conduct their activities IAW ORARNGR 420-47, Hazardous Material and Waste Management Plan. The plan describes specific and detailed requirements for these wastes to include the storage, use, transportation, disposal, reporting, and documentation.
b. Each ORARNG facility must be evaluated annually to determine its HW Generator status. In order to do this, each HW generator must annually identify all waste streams in their operations and determine which wastes are HW. Determinations must be documented on AGO Form 200-1-6 and, once complete, filed at Annex K to Chapter 20 of this pamphlet. Based on the results, the identified "Facility EPOC" must determine the "generator status" of the facility, based on the accumulated information from all activities at the facility. Facilities meeting SmallQuantity and LargeQuantity HW generator criteria must obtain an Identification Number from EPA and/or Oregon DEQ. Coordination with AGI-ENV is required. HW must be properly stored, packaged, handled, manifested, transported and disposed of IAW requirements.
c. All wastes shall be identified in determining HW generation. Common wastes which are normally “hazardous waste” include, but are not limited to parts cleaning solvents, batteries, used battery electrolyte, used oil and oil filters, waste fuel, protective mask filters, unused MRE heaters to be discarded, M256 test kits, and decontamination agents, such as DS-2 (decontamination solution) and STB (super-tropical bleach).
d. Personnel must be trained, provided personal protective equipment and clothing, and afforded medical monitoring when required by regulation.
(1) HW generators must post emergency information for prompt response in the event of an accidental release or other emergency incident at the facility. Information must be posted at every telephone at the facility. When completed, AGO Form 200-1-7 meets this requirement.
(2) Waste accumulation and storage areas must be defined, kept clean, and inspected weekly. When maintained, AGO Form 200-1-8 documents required inspections.
(3) A contingency plan must be in place so personnel respond to HW spills or other emergencies. Spills and spill plans are addressed in Chapter 11 of this pamphlet.
e. Various reports, as described in Chapter 8 of ORARNGR 420-47, must be prepared when certain criteria are met. ORARNGR 420-47 must be reviewed for requirements.
8-5. RESPONSIBILITIES
a. AGI-ENV will:
(1) Interpret applicable federal, state, local and Army waste management regulations, and maintain a management plan describing requirements for ORARNG units and facilities.
(2) Provide appropriate training for EPOCs and SMWs in hazardous material and waste management requirements.
(3) Ensure required reports are prepared by affected personnel and submitted to appropriate regulatory agencies and AGI-ENV.
(4) Routinely visit all ORARNG sites to ensure proper compliance.
(5) Coordinate with Facility EPOCs and obtain EPA/DEQ HW Generator Identification Numbers for facilities meeting requirements.
b. Unit/Facility EPOCs and State Maintenance Workers will:
(1) Obtain training in HW requirements contained in Chapter 19 of this pamphlet, and ensure compliance in unit operations, facilities maintenance, and tenants and transient activities.
(2) Assist AGI-ENV in identifying and training appropriate personnel in HM and HW management procedures, as required by regulation or in order to ensure compliance.
(3) Implement necessary waste management activities.
(4) Prepare and submit required reports, as necessary.
(5) Request assistance from AGI-ENV in obtaining HW Generator Identification Numbers for facilities that reach Small-Quantity or Large-Quantity HW Generator status.
c. Facility EPOC will:
(1) Ensure waste streams are annually identified on AGO Form 200-1-6 and evaluated to determine which are classified and must be managed as “hazardous” waste. File completed copies of this form at Annex K to Chapter 20 of this pamphlet.
(2) Designate a HW accumulation area (or areas) for the facility.
(3) Ensure HW accumulation areas and containers are inspected weekly, inspections are documented on AGO Form 200-1-8, and completed forms are filed at Annex N to Chapter 20 of this pamphlet.
(4) Ensure emergency response information (AGO Form 200-1-7) is completed and available at each telephone at the facility. File current, completed form at Annex M to Chapter 20 of this pamphlet.
(5) Prepare a plan for responding to HW spills or other accidents. This requirement can be met by completing a Facility Spill Response Plan (Appendix B, ORARNGR 210-6) for facilities not subject to an ICP. File completed plans at Annex Q to Chapter 20 of this pamphlet.
(6) Ensure personnel assigned HW handling duties are trained. Document training on AGO Form 200-1-13. File completed forms at Annex X to Chapter 20 of this pamphlet.
8-6. KEY QUESTIONS YES NO N/A
a. Have wastes generated by all activities been evaluated to
determine those to be managed as "hazardous waste"? ______
b. Is the determination of HW documented on AGO Form
200-1-6 and filed at Annex K (Facility EPOC)? ______
c. Has "generator status" been determined (Facility EPOC)? ______
d. Is AGO Form 200-1-7 complete and available at
each telephone at the facility, and in Annex M? ______
e. Has a DEQ Toxic Use Reduction/HW Reduction Plan
been prepared for the facility (Facility EPOC)? ______
f. If so, is it current and on file at Annex L (Facility EPOC)? ______
8-6. KEY QUESTIONS (continued) YES NO N/A
g. Is a DEQ Registration Verification Report (RVR) required? ______
h. If so, is it current and filed at Annex L? ______
i. If a "SmallQuantity" or "LargeQuantity" HW generator,
does the facility have a "HW Generator ID Number"? ______
j. If no, has the Facility EPOC requested a number through
the chain of command to AGIENV, in writing? ______
k. If yes, is documentation on file in Annex L? ______
l. Do personnel understand how to identify HW and the
procedures used in HW management and turnin? ______
m. Has one or more HW accumulation areas been defined (unit, activity or facility-wide)? ______
n. Is AGO Form 200-1-8 used to document weekly inspection
of accumulation areas and stored containers? ______
o. Are wastes segregated to ensure HW is not disposed of
as solid waste? ______
8-7. ENVIRONMENTAL COMPLIANCE NOTEBOOK
The following documents should be filed in the appropriate annexes of this pamphlet:
(1) A completed AGO Form 200-1-6, HW Determination Worksheet [All] (Annex K)
(2) A completed AGO Form 200-1-7, Emergency Information [All] (Annex M)
(3) A completed AGO Form 200-1-8, Weekly Inspection Sheet [All] (Annex N)
(4) EPA/OR HW Generator ID Number for the Facility [Facility EPOC] (Annex K)
(5) Facility Toxic Use Reduction/HW Reduction Plan [Facility EPOC] (Annex L)
(6) A copy of the annual TURHWR Progress Report [Facility EPOC] (Annex L)
(7) Unit HW SOP, if one has been developed [Unit EPOC] (Annex K)
(8) Generator copies of all HW manifests and/or DA Forms 2765-1 [Unit EPOC] (Annex K)
8-8. TECHNICAL ASSISTANCE. Technical assistance on the ORARNG Hazardous Waste Management Program can be obtained from the Hazardous Waste Management Specialist in the Environmental Section (AGI-ENV), (503) 584-3862.
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