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CHAPTER 6 HAZARDOUS WASTE MANAGEMENT

6-1. SCOPE.

This chapter identifies requirements and responsibilities applicable to the prevention and control of pollution from the generation, transportation, treatment, storage, or disposal of hazardous waste. The chapter serves as the basis for implementation of the Environmental Protection Agency (EPA) hazardous waste regulations, the Resource Conservation and Recovery Act (RCRA) of 1976, as amended. Guidance on underground storage tanks (40 CFR 280) is at chapter 2 of this manual. The following Federal regulations have been promulgated by EPA under RCRA to implement the National Hazardous Management Program:

40 CFR, Part 260 Hazardous Waste Management System: General

40 CFR, Part 261 Identification and Listing of Hazardous Waste

40 CFR, Part 262 Standards Applicable to Generators of Hazardous Waste

40 CFR, Part 263 Standards Applicable to Transporters of Hazardous Waste

40 CFR, Part 264 Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities

40 CFR, Part 265 Interim Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Dis- posal Facilities

40 CFR, Part 267 Interim Standards for Owners and Operators of New Hazardous Waste Land Disposal Facilities

40 CFR, Part 268 Land Disposal Restrictions

40 CFR, Part 122 EPA Administered Permit Programs

40 CFR 266 Standards for Management of Specific Hazardous Wastes and Facilities

40 CFR 270 Regulations for Federally Advised Hazardous Waste Permit Programs

40 CFR 271 Requirements for Authorization of State Hazardous Waste Programs

6-2. BACKGROUND.

RCRA provides a national strategy for management of hazardous waste (HW). The strategy, as implemented by EPA, involves the identification, management and tracking of HW from the time it is generated to the time it is finally and properly disposed. Activities regulated include hazardous waste generation, transportation, storage, treatment and disposal. The regulatory mechanism that ties all of these activities together is the "manifest", a document describing the waste which accompanies the waste until disposal, after which it is returned to the generator to indicate final disposition. A generator of a hazardous waste must use the manifest to track the wastes from the point of generation to the point at which it arrives at the permitted facility. Another important feature is the assignment by EPA of identification numbers to generators, transporters, storers, treaters, and disposers of HW. EPA uses the identification numbers, the manifest, and specific reports to track and manage hazardous waste from the point of generation to the point of disposal. RCRA requires that Federal facilities comply with all Federal, state, interstate and local requirements, both substantive and procedural, concerning control and management of HW. RCRA provides that EPA may transfer their responsibility for implementation and enforcement of HW programs to the states. If a state has a program, and EPA has not approved the state program, DLA must comply with both Federal and state requirements. EPA-authorized state programs are often significantly more stringent than the EPA's.

6-3. POLICY

a. Material will be purchased and used in such a manner in order to minimize generation of waste, conserve resources, and prevent harmful effects on human health and the environment.

b. The use of toxic or hazardous material will be limited to the extent practical. The substitution of nonhazardous materials or items is encouraged.

c. Safe and environmentally acceptable methods will be used to store and ultimately dispose of hazardous materials.

d. Proper training will be provided to personnel who manage, use, store, or dispose of hazardous materials.

e. Materials which meet the definition of hazardous waste will be managed in accordance with Federal or state hazardous waste management regulations. f. Hazardous waste will be recycled or reused to the greatest extent possible. g. DLA installations will not be used for the storage or disposal of non-DoD-owned toxic or hazardous materials.

6-4. RESPONSIBILITIES.

Heads of DLA-managed PLFAs will:

a. Manage hazardous waste in accordance with the policies and procedures of this manual.

b. Prepare and periodically update an installation-wide hazardous waste management plan in accordance with the procedures of this chapter.

6-5. PROCEDURES

a. Generator Requirements:

(1) Applicability of Regulations. A solid waste generator is defined in 40 CFR 261.2, Definition of Solid Waste. Within DLA, a generator is considered to be the installation or activity on an installation which produces a regulated hazardous waste. The generator is also commonly considered to be the activity which turns hazardous waste into the DRMO for disposal. The DRMO itself can also be the generator in some instances, such as when hazardous materials survive the disposal process and must be disposed of as a hazardous waste. In any event, the generator of a waste must first determine if the waste being generated is hazardous using the following guidelines:

(a) Determine if the waste is excluded from regulation under 40 CFR 261.4, exclusions.

(b) Determine if the waste is listed as a hazardous waste in Subpart D of 40 CFR 261 or in applicable state regulations.

(c) If the waste is not listed as a hazardous waste in Subpart D of 40 CFR 261, Lists of Hazardous Wastes, a determination must be made whether the waste is identified in Subpart C of 40 CFR 261, Characteristics of Hazardous Wastes, by either testing the waste or applying knowledge of the hazard characteristic of the waste. The four characteristics discussed in Subpart C of 40 CFR 261 are ignitability, corrosivity, reactivity, and toxicity.

(d) If the waste is hazardous, the next determination is whether or not the threshold monthly generation rates or accumulation quantities in 40 CFR 261.5, Special Requirements for Hazardous Waste Generated by Conditionally Exempt Small Quantity Generators, are exceeded. If the threshold rates or accumulation quantities (100 kilograms of hazardous waste in a calendar month) are exceeded, the generator and the waste are entirely regulated under RCRA; if not exceeded, the generator is a "conditionally exempt small quantity generator" and subject to RCRA requirements only to the extent indicated in 40 CFR 261.5. This means that the hazardous waste must: (1) be treated and disposed of onsite in facilities that are permitted by EPA or a state or have interim status or, (2) be delivered to an offsite treatment, storage or disposal facility which meets the same requirements. In the case where threshold hazardous waste monthly generation rates or accumulation quantities are exceeded, the generator is subject to all RCRA requirements pertaining to generators. These generator requirements include the following:

(1) Obtain an EPA Identification Number. All DLA generators were required to file a "Notification of Hazardous Waste Activity with EPA" by 19 August 1980 and were subsequently issued identification numbers by EPA. It should also be noted that state requirements can be more stringent and may require notification to the state of generator status.

(2) Comply with Manifest Requirements. A generator who transports, or offers for transportation, hazardous waste for offsite treatment, storage, or disposal must prepare a manifest before transporting the waste offsite. The manifest must contain all of the following information:

(a) Generator's USEPA or state ID Number manifest document number.
(b) Total number of pages.
(c) The generator's name, mailing address, and telephone number.
(d) The name and EPA identification number of each transporter.
(e) The name, address, and EPA identification number of the designated facility and an alternate facility, if any.
(f) The description of the waste(s) (e.g., proper shipping name, Hazard Class and ID Number) required by regulation of the U.S. Department of Transportation in 49 CFR 172.101, 172.203.
(g) The total quantity of each hazardous waste by units of weight or volume, and the type and number of containers as loaded into or onto the transport vehicle.
(h) Certifications must be provided on the manifest that the materials have been properly classified, packaged, and labeled and are in proper condition for transportation according to the applicable regulations of the Department of Transportation and EPA. Further, the generator must certify that waste minimization programs are in effect and that land ban restrictions will be complied with.
(i) The generator must also complete the shaded portion of the manifest giving all state required information.

(2) Properly Package and Label Containers. The following pre-transport requirements must be adhered to before a generator can transport hazardous waste or offer hazardous waste for transportation offsite:

(a) Package the waste in accordance with the applicable Department of Transportation regulations on packaging under 49 CFR Parts 173, 178, and 179.

(b) Label each package in accordance with the applicable Department of Transportation regulations on hazardous materials under 49 CFR Part 172.

(c) Mark each package of hazardous waste in accordance with the applicable Department of Transportation regulation on hazardous materials under 49 CFR Part 172.

(d) Label each container of 110 gallons or less used in such transportation with the following information as required by 49 CFR 172.304 (some states have other specific labelling requirements):

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_______________________________
Manifest Document Number____________________________________

(e) Placard or offer the initial transporter the appropriate placards according to Department of Transportation regulations for hazardous materials under 49 CFR Part 172, Subpart F.

(3) Hazardous Wastes Generators. A DLA ac- tivity which generates more than 1000 kg of hazardous waste or 1 kg acutely hazardous waste per month may accumulate hazardous waste onsite for 90 days or less without a permit or without having interim status provided that:

(a) The waste is placed in containers and the generator complies with Subpart I, Use and Management of Containers, of 40 CFR Part 265, or waste is placed in tanks and the generator complies with Subpart J, Tanks, of 40 CFR Part 265 except 265.193, Waste Analysis and Trial Tests.

(b) The date upon which each period of accumulation begins is clearly marked visible for inspection on each container.

(c) While being accumulated onsite, each container and tank is labeled or marked clearly with the words, "Hazardous Waste."

(d) The activity complies with the requirements for owners or operators in Subparts C, Preparedness and Prevention, and Subpart D, Contingency Planning and Emergency Procedures, in 40 CFR Part 265 and with 265.16, Personnel Training.

(4) Time Limitations for Generators

(a) Hazardous Waste must be taken to a permitted facility within 90 days. A DLA activity which accumulates hazardous waste for more than 90 days is an operator of a storage facility and is subject to the requirements of 40 CFR Parts 264 and 265 and the permit requirements of 40 CFR Part 122.

(b) A generator may accumulate up to 55 gallons of hazardous waste or one quart of acutely hazardous waste in containers at or near any point of generation without a permit (some states such as Delaware do not have this provision) or being subject to the 90-day requirement provided that:

(1) The containers are in good condition, compatible with the hazardous waste and kept closed except when adding waste.

(2) The container is marked "Hazardous Waste."

(3) The generator must move the container to a permitted storage area within 3 days of filling it.

(c) A DLA activity which generates greater than 100 kg but less than 1000 kg of hazardous waste in a month may accumulate hazardous waste onsite for up to 180 days (or 270 days if the waste must be shipped more than 200 miles for disposal) provided that:

(1) The quantity of waste accumulated never exceeds 600 kg.

(2) The generator complies with the preparedness and prevention requirements of Subpart C, 40 CFR 265, and has a spill contingency plan.

(3) Anyone who generates greater than 100 kg, but less than 1000 kg of hazardous waste in a month and who accumulates quantities exceeding 6000 kg or accumulates for longer than 180 or 270 days is an operator of a storage facility and is subject to the requirements of 40 CFR 264, 265, and 270.

(5) Recordkeeping and Reporting. Recordkeeping and reporting requirements are applicable to installations at which hazardous waste is generated. DLA PLFAs will ensure that these and other requirements are complied with by tenant activities. DRMOs and other DLA activities which are tenants will ensure that needed information is maintained and provided to the host reporting activity. The recordkeeping and reporting requirements are as follows:

(a) A generator must keep a copy of each signed manifest for 3 years or longer if required by the state. This signed copy must be retained as a record for at least 3 years from the date the waste was accepted by the initial transporter.

(b) A generator must keep a copy of each Biennial Report and Exception Report (see 40 CFR 262.42) (Exception Reporting) for a period of at least 3 years from the due date of the report.

(c) A generator must keep records of any test results, waste analyses, or other determinations made in accordance with 40 CFR 262.11, Hazardous Waste Determination, for at least 3 years from the date that the waste was last sent to onsite or offsite treatment, storage, or disposal.

(d) The periods of retention referred to in this section are extended automatically during the course of any unresolved enforcement action or as requested by EPA.

(e) A generator who ships hazardous waste offsite must submit Biennial Reports. Generators will report as follows:

(1) Use EPA Form 8700-13A according to the instructions on the form.

(2) Submit to the Regional Administrator for the Region in which the generator is located.

(3) Submit no later than March 1 of each even-numbered year.

(f) Any generator who treats, stores, or disposes of hazardous waste onsite must submit a Biennial Report covering those wastes in accordance with the provisions of 40 CFR Parts 264,265,266, and 270.

(g) A generator who does not receive a copy of the manifest with the handwritten signature of the owner or operator of the designated facility within 35 days of the date transported must contact the transporter and, as necessary, the owner or operator of the facility to determine the status of the hazardous waste. If the signed manifest is not returned within 45 days, the generator must submit an Exception Report to the EPA Regional Administrator. An Exception Report must include a cover letter explaining efforts taken to locate the waste and a copy of the manifest.

b. Transporter Requirements. This section establishes standards which apply to persons transporting hazardous waste within the United States if the transportation requires a manifest under 40 CFR Part 262. These standards do not apply to onsite transportation of hazardous waste at DLA activities or by generators, owners, or operators of permitted hazardous waste management facilities.

(1) Applicability of Regulations. A transporter of hazardous waste must also comply with 40 CFR Part 262, Standards Applicable to Generators of Hazardous Waste, if that person:

(a) Transports hazardous waste into the U.S. from abroad.

(b) Mixes hazardous wastes of different DOT shipping descriptions by placing them into a single container.

(2) General Restrictions

(a) A transporter must not transport hazardous waste without having received an EPA identification number.

(b) A transporter of hazardous waste must comply with the manifest requirements of 40 CFR 263.20, the Manifest System, and 263.21, Compliance with the Manifest.

(c) A transporter of hazardous waste must comply with recordkeeping requirements of 40 CFR 263.22, Recordkeeping.

(d) In the event of a discharge of hazardous waste during transportation, the transporter must take appropriate immediate action to protect human health and the environment (e.g., notify local authorities, like the discharge area).

(e) An air, rail, highway, or water transporter who has discharged hazardous waste must:

(1) Give notice, if required by 49 CFR 171.15, to the National Response Center (800-424-8802 or 202-426-2675).

(2) Report in writing as required by 49 CFR 171.16 to the Director, Office of Hazardous Materials Regulations, Materials Transportation Bureau, Department of Transportation, Washington, DC 20590.

(3) A transporter must clean up any hazardous waste discharge that occurs during transportation or take such action as may be required or approved by Federal, state, or local officials so that the hazardous waste discharge no longer presents a hazard to human health or the environment.

c. Treatment, Storage and Disposal Requirements. RCRA requires that owners or operators of hazardous waste treatment, storage, or disposal (TSD) facilities notify EPA to obtain an identification number and further obtain a permit to continue operation or initiate new operations. EPA has developed a two-part permitting procedure where a Part A application confers "interim status" to an existing TSD Facility allowing operation until a Part B application for final permit is made and approved. The permitting procedures are contained in 40 CFR Parts 270 and 271. TSD facilities may significantly change or expand their operations and remain under "interim status" only with the approval of EPA Regional Offices. Interim status cannot be conferred on a new TSD facility if construction commenced after 19 November 1980. In such instances, a final permit must be applied for and obtained before construction may begin.

d. Requirements Under Interim Status. Interim status requirements are contained in 40 CFR Part 265 and are summarized below:

(1) General Waste Analysis (40 CFR 265.13). Before an owner or operator treats, stores, or disposes of any hazardous waste, a detailed chemical and physical analysis of a representative sample of the waste must be obtained. At a minimum, this analysis must contain all the information which must be known to treat, store, or dispose of the waste in accordance with the requirement of 40 CFR Pat 265. The owner or operator must develop and follow a written waste analysis plan which describes the procedures which will be followed to comply with the above.

(2) Security (40 CFR 265.14). The owner or operator must prevent the unknowing entry, and minimize the possibility for any unauthorized entry, onto the active portion of the TSD facility.

(3) General Inspection Requirements (40 CFR 265.15). The owner or operator must inspect the TSD facility for malfunctions and deterioration, operator errors, and discharges which may cause: (1) release of hazardous waste constituents into the environment or, (2) a threat to human health. The owner or operator must develop and follow a written schedule for inspecting all monitoring equipment, safety, and emergency equipment, security devices, operating, and structural equipment (such as dikes and sump pumps) that are important to preventing, detecting, or responding to environmental or human hazards.

(4) Personnel Training (40 CFR 265.16). Facility personnel must successfully complete a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility's compliance with the requirements of 40 CFR Part 265. Training must be complete within six months of starting and be reviewed annually. Records for each employee must be maintained until closure for current employees and for three years for former employees.

(5) General Requirements of Ignitable, Reactive, or Incompatible Wastes (40 CFR 265.17). The owner or operator must take precautions to prevent accidental ignition or reaction of ignitable or reactive waste. This waste must be separated and protected from sources of ignition or reaction including, but not limited to: open flames, smoking, cutting and welding, hot surfaces, frictional heat, sparks (static, electrical, or mechanical), spontaneous ignition (e.g., from heat-producing chemical reaction), and radiant heat.

(6) Preparedness and Prevention (40 CFR Parts 265.30 through 265.37). These sections discuss the following:

Maintenance and Operation of Facility Required Equipment
Testing and Maintenance of Equipment
Access to Communications or to Alarm Systems
Required Aisle Space
Arrangements with Local Authorities

(7) Contingency Plan and Emergency Procedures (40 CFR Parts 265.50 through 265.56). These sections discuss the following:

Purpose and Implementation of Contingency Plan
Content of Contingency Plan
Copies of Contingency Plan
Emergency Coordination
Emergency Procedures

(8) Recordkeeping and Reporting (40 CFR Parts 265.73 through 265.77).

(a) Operating Record. The owner or operator must keep a written operating record at his facility.

(b) Availability, Retention, and Disposition of Records. All records including plans required under this part must be furnished upon request and made available at all reasonable times for inspection, by any officer, employee, or representative of EPA who is duly designated by the Administrator.

(c) Biennial Report. The owner or operator must prepare and submit a single copy of a biennial report to the Regional Administrator by March 1 of each even-numbered year.

(d) Additional Reports. In addition to submitting the Biennial Report and unmanifested waste report, the owner or operator must also report to the Regional Administrator:

--Release, fires, and explosions
--Ground-water contamination and monitoring data
--Facility closure

(9) Closure and Post Closure (40 CFR Parts 265.11 through 265.120). Host activities normally maintain closure plans for tenants, such as DRMOs. In either event, the owner or operator must close his facility in a manner that:

(a) Minimizes the need for further maintenance.

(b) Controls, minimizes, or eliminates the post-closure escape of hazardous waste, hazardous waste constituents, leachate, contaminated rainfall, or waste decomposition products to the ground or surface waters or to the atmosphere.

(10) Use and Management of Containers (Subpart I, 40 CFR Parts 265.170 through 265.177). The following will be complied with:

(a) Condition of Containers. If a container holding hazardous waste is not in good condition, or if it begins to leak, the owner or operator must transfer the hazardous waste from this container to a container that is in good condition, or manage the waste in some other way that complies with the requirements of 40 CFR 265.

(b) Compatability of Waste with Container. The owner or operator must use a container mad of or lined with materials which will not react with, and are otherwise compatible with, the hazardous waste to be stored, so that the ability of the container to contain the waste is not impaired.

(c) Management of Containers. A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste. A container holding hazardous waste must not be opened, handled, or stored in a manner which may rupture the container or cause it to leak.

(d) Inspection. The environmental officer must inspect areas where containers are stored at least weekly, looking for leaks and for deterioration caused by corrosion or other factors. The environmental officer must make and maintain records of inspections.

(e) Special Requirement for Ignitable or Reactive Waste. Containers holding ignitable or reactive waste must be located at least 15 meters (50 feet) from the facility's property line.

(f) Special Requirements for incompatible wastes.

(1) Incompatible wastes must not be placed in the same container.

(2) Hazardous waste must not be placed in an unwashed container that previously held an incompatible waste or material.

(3) A storage container holding hazardous waste that is incompatible with any waste or other materials stored nearby in other containers, piles, open tanks, or surface impoundments, must be separated from the other materials or protected from them by means of a dike, berm, wall, or other device.

e. Requirements Under Final Status. Final status standards for TSD Operators are similar in content and nature to the interim status standards discussed above; however, they cover areas not discussed under interim status requirements and are more stringent. Major areas not covered under interim status that are included in the final standards are:

(1) Location Standards (40 CFR 264.18). The two areas discussed in this section are:

(a) Seismic consideration. Portions of new facilities where treatment, storage, or disposal of hazardous waste will be conducted must not be located within 61 meters (200 feet) of a fault which has had displacement in Holocene time.

(b) Floodplains. A facility located in a 100-year flood plain must be designed, constructed, operated, and maintained to prevent washout of any hazardous waste by a 100-year flood unless the owner or operator can demonstrate to the Regional Administrator that procedures are in effect which will cause the wastes to be removed safely, before flood waters can reach the facility, to a location where the wastes will not be vulnerable to floodwaters.

(2) Use and Management of Containers (Subpart I, 40 CFR Parts 264.170 through 264.178). Major additions to this Subpart not discussed under interim status are:

(a) Containment (40 CFR 264.175).

(1) Container storage area must have a containment system that is designed and operated as described below.

(2) A base must underlie the containment which is free of cracks or gaps and is sufficiently impervious to contain leaks, spills, and accumulated precipitation until the collected material is detected and removed.

(3) The base must be sloped or the containment system must be otherwise designed and operated to drain and remove liquids resulting from leaks, spills, or precipitation, unless the containers are elevated or are otherwise protected from contact with accumulated liquids.

(4) The containment system must have sufficient capacity to contain 10 percent of the volume of containers or the volume of the largest container, whichever is greater. Containers that do not contain free liquids need not be considered in this determination.

(5) Run-on into the containment system must be prevented unless the collection system has sufficient excess capacity to contain any run-on which might enter the system.

(6) Spilled or leaked waste and accumulated precipitation must be removed from the sump or collection area in as timely a manner as is necessary to prevent overflow of the collection system. If the collected material is a hazardous waste under 40 CFR 261, it must be managed as a hazardous waste. If the collected material is discharged through a point source to waters of the United States, it is subject to the requirements of chapter 4 of this manual.

(b) Storage areas that store containers holding only wastes that do not contain free liquids need not have a containment system provided that:

(1) The storage area is sloped or is otherwise designed and operated to drain and remove liquid resulting from precipitation.

(2) The containers are elevated or are otherwise protected from contact with accumulated liquid.

(3) Closure (40 CFR 264.178). At closure, all hazardous waste and hazardous waste residues must be removed from the containment system. Remaining containers, liners, bases, and soil containing or contaminated with hazardous waste or hazardous waste residues must be decontaminated or removed.

(4) Corrective Action (RCRA 3004u). Any permit issued after 8 November 1984 must require corrective action for all releases of hazardous waste from any solid waste management unit regardless of when the waste was placed in the unit. The owner of a permitted facility must institute corrective action beyond the facility boundary, where necessary, to protect human health and the environment. Corrective actions at DRMOs or other DLA activities which are tenants is the responsibility of the host activity. Corrective actions will be undertaken in accordance with (chapter 9) Defense Environmental Restoration Program.

f. Hazardous Waste Management Plan

(1) DLA activities which generate hazardous waste will develop a hazardous waste management plan for the purpose of ensuring proper management of hazardous waste at each point of generation. The plan will consist of a installation-wide inventory of hazardous waste generation points; an evaluation of the costs associated with the use of hazardous materials and potential alternatives (economic alternatives); a review of the adequacy of personnel training and facilities at each point of generation of waste; a review of the adequacy of waste minimization procedures; and a list of recommendations and corrections. The hazardous waste management plan will include as applicable the waste analysis plan, inspection plan, training plan, spill prevention control and counter measures plan, and installation spill contingency plan. The HW management plan will be prepared by the installation environmental coordinator with the assistance and coordination of the hazardous waste management committee.

(2) DLA installation environmental officers will serve as the Installation Hazardous Waste Program Coordinator.

(3) A Hazardous Waste Management Committee will be established for the purpose of ensuring that:

(a) Installation-wide sources of HW are identified.

(b) Appropriate HW training is provided to personnel.

(c) Opportunities for waste minimization are reviewed for each activity generating HW.

(d) Knowledge of regulatory requirements, DRMO turn-in procedures, and the like are exchanged. The committee will consist of representatives from each activity which generates HW, including representatives from the environmental office, safety office, depot operations, fire chief, servicing DRMO, and tenant activities.

g. Waste Disposal

(1) Hazardous waste and excess hazardous materials will be turned in to the DRMO for disposal in accordance with policies and procedures in DoD 4160.21-M, Defense Reutilization and Marketing Manual, chapter IX.

(2) DLA activities which must dispose of small quantities of unserviceable and uncontaminated material will refer to the Hazardous Material Information System (HMIS) Disposal File. Disposal guidance for some materials is also available by contacting the U.S. Army Environmental Hygiene Agency, Aberdeen Proving Ground, MD 21010.

h. Storage and Disposal of Non-DoD-Owned Hazardous or Toxic Materials at DLA Activities. In accordance with the policy of this chapter, DLA activities are restricted from accepting for storage and disposal non-DoD-owned toxic or hazardous materials. The storage, disposal, transportation, and rendering safe of such material reported or discovered in areas outside of DLA activities are primarily the responsibility of civil authorities. DRMS or other DLA PLFAs which are involved in a remedial action as a potentially responsible party (see paragraph 9-4c) may not transfer non-DoD-owned hazardous materials to a DoD installation. Exceptions to this policy will be given in certain instances, such as emergency lifesaving assistance to civil authorities, on the temporary storage or disposal of explosives. Requests for exception to this policy should be forwarded to DLA-WE.

TABLE 6.1

HAZARDOUS WASTE GENERATION CATEGORIES

REF: RCRA, 1984 Amendments and 40 CFR 261-265

CLASSIFICATION QUANTITY OF
HAZARDOUS WASTE GENERATED
(Kilograms/month)
RESPONSIBILITIES UNDER RCRA
     
100 Kg/mo
Generator
Generates or accumulates less than
100kg (220 lbs) of HW and less than
1 Kg (2.2lbs) of Acute HW
Must either treat waste onsite and/or dispose of it in an
EPA-permitted HW disposal facility and/or dispose of it in
a facility permitted or licensed by state to manage
municipal or industrial waste.
100-1000Kg/mo
Generatro
Generates or accumulates more than
100kg (220 lbs) of HW and less than
1000 Kg (2.2 lbs) of Acute HW
Waste must be disposed of only in a facility which is
permitted, licensed, or registered by a state to manage
municipal or industrial solid waste. Waste generated shall
be accompanied by a copy of the EPA Uniform Manifest
form signed by the generator.
Generator Generates of accumulates more than
1000kg of HW or greater than 1 Kg of
Acute HW
Comply with all regulations promulgated by EPA and
DOT regarding HW notification, generation, treatment,
storage, transportation, and disposal.

(a) All generators were required to file a "Notification of
Hazardous Waste Activity" with EPA by 19 August 1980
and were subsequently issued identification numbers by
EPA.
(b) All HW must be shipped by manifest. (40 CFR 262)
(c) Are responsible for reporting HW operations and
recordkeeping.
(40 CFR 262) TABLE 5.2 OUTLINES SPECIFIC
REQUIREMENTS FOR "GENERATORS" BASED ON
TYPE OF OPERATION.

 

TABLE 6.2

HAZARDOUS WASTE GENERATION REQUIREMENTS

NOTE: THIS TABLE IS FOR ACTIVITIES WHICH ARE CLASSIFIED BY EPA AS FULL GENERATORS OF HW, SEE TABLE 5.1

CLASSIFICATION
GENERATOR
STORAGE/ACCUMULATION
STATUS
RESPONSIBILITIES UNDER RCRA
     
Generates or
accumulates
or Kg of Acute
Satellite Accumulation Area 1. HW container in good condition (40 CFR 265.171)
2. HW container be made out of a material compatible with the hazardous waste to be stored (40 CFR 265.172).
3. HW containers must be closed except when it is necessary to add or remove waste (40 CFR 265.173(a)).
4. Mark the container either with the words "Hazardous Waste" or with other words that identify the contents of the container (40 CFR 262.34 (c)(ii)).
5. Restrict onsite accumulation to less than 55 gallons of hazardous waste or one quart acutely hazardous waste.
6. Move quantities greater than 55 gallons to temporary or permitted storage site within 3 days.
  Less than 90 days, onsite
area (temporary)
1. The waste is placed in containers and accumulation the generator complies with 40 CFR 265, Subpart I. This Subpart details the condition of con- tainers, inspections, and con- tainer requirements for special wastes.
2. If the waste is placed in tanks, the generator must comply with 40 CFR 265, Subpart J.
3. The accumulation start date is clearly marked and and visible (40 CFR 262.34(a) (2)).
4. While being accumulated onsite, each container and tank is labeled and marked clearly with the words "Hazardous Waste" (40 CFR 262.34(a)(3)).
5. The generator complies with the requirements for operators in 40 CFR 265, Subparts C and D.
6. The generator complies with the training requirements in 40 CFR 265.16.
  Permitted Treatment, Storage
(TSD) Facility
Must comply with the requirements and disposal requirements of 40 CFR 270.

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