73500 - Appendix 7 - Hazardous Waste Management Plan_.pdf

HEADQUARTERS 78TH AIR BASE WING

ROBINS AIR FORCE BASE, GEORGIA 31098-2700

ROBINS AIR FORCE BASE HAZARDOUS

WASTE MANAGEMENT PLAN

(SHORT TITLE: RAFB HWMP)

1 July 2021

OPR: 78 AIR BASE WING CIVIL ENGINEERING

GROUP (78 CEG/CEIER)

CUI

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About This Plan

This installation-specific Environmental Management Plan (EMP) is based on the U.S. Air Force’s (AF) standardized Hazardous Waste Management Plan (HWMP) template. This plan is not an exhaustive inventory of all hazardous waste (HW) requirements and practices. Where applicable, external resources, including Air Force Manuals (AFMANs); Air Force Instructions (AFIs); AF Playbooks; federal, state, local and Final Governing Standards (FGS); and permit requirements, as applicable, are referenced.

Each section of this HWMP plan begins with standardized, AF-wide “common text” language that addresses AF and Department of Defense (DoD) policy and federal requirements. This common text language is restricted from editing to ensure that it remains standard throughout all plans. The common text language is maintained and updated by the designated Office of Primary Responsibility (OPR) with assistance from the Office of Collateral Responsibility (OCR), as appropriate. Immediately following the

AF-wide common text sections, are Installation sections. The Installation sections contain installation-specific content to address state, local and installation-specific requirements. Installation sections are unrestricted and are maintained and updated by AF environmental Installation Support Teams (ISTs) and/or installation personnel.

This document is optimized to be accessed and viewed electronically. The eDASH website at https://cs1.eis.af.mil/sites/edash/ is the primary communication tool for AF EMPs.

https://cs1.eis.af.mil/sites/edash/

TABLE OF CONTENTS

DOCUMENT CONTROL

1.0 OVERVIEW AND SCOPE

Introduction

2.0 INSTALLATION PROFILE

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

4.0 GENERAL ROLES AND RESPONSIBILITIES

5.0 TRAINING

6.0 RECORDKEEPING AND REPORTING

7.0 PROCEDURES

7.1 Waste Inventory

7.2 Waste Identification

7.3 Container Management

7.4. Labeling and Marking

7.5 Accumulation Area Management

7.6 Transportation

7.7 Turn In/Disposal

7.8 Inspection

7.9 Waste Minimization

7.10 Preparedness and Prevention

7.11 Waste Specific Procedures

8.0 REFERENCES

9.0 ACRONYMS

10.0 DEFINITIONS

11.0 INSTALLATION-SPECIFIC CONTENT

APPENDICES

Appendix A – Emergency Phone Numbers

Appendix B – 90-Day Accumulation Sites (EHWAS)

Appendix C – 90-Day Accumulation Roll-off Units

Appendix D – Figures

Appendix E – Potentially Incompatible Wastes

Appendix F – Empty Container Management

DOCUMENT CONTROL

Record of Updates – The HWMP is updated as changes to waste generation and management practices occur, including those driven by changes in applicable regulations.

Record of Updates

Change No. Nature of Change Date of Change Approved By:

Record of Annual Review – In accordance with (IAW) AFMAN 32-7002, Environmental Compliance and Pollution Prevention, this plan is reviewed annually, updated as appropriate, and approved by the

Environmental Safety and Occupational Health Council (ESOHC). Formatting and administrative changes do not require ESOHC review.

Record of ESOHC Annual Review

Review Date Review Participants Notes/Remarks Result in Plan

Update? (Yes or No)

3/2/2018 CFT NO

1.0 OVERVIEW AND SCOPE

This HWMP contains procedures for management of HW. In lieu of federal, state, or FGS requirements, AFMAN 32-7002, Environmental Compliance and Pollution Prevention, acts as the main driver for the

HWMP. The HW Playbook serves as supplemental guidance to this plan.

Installation Supplement – Overview and Scope

Introduction

Congress passed environmental laws containing comprehensive requirements for the control of hazardous materials (HM) and hazardous waste (HW). These federal statutes include the

Resource Conservation and Recovery Act of 1976 (RCRA); the 1984 Hazardous and Solid Waste

Amendments; the Toxic Substance Control Act (TSCA); the Comprehensive Environmental

Response, Compensation, and Liability Act (CERCLA); and the Federal Facilities Compliance

Act (FFCA) of 1992. Federal regulations promulgated by the U.S. Environmental Protection

Agency (EPA) are based upon the requirements established by the federal statutes listed above.

U.S. Air Force (USAF) installations that do not qualify as small quantity generators of HW under

EPA and State criteria shall develop a HWMP in accordance with AFMAN 32-7002, Environmental Compliance and Pollution Prevention, and the HW turn-in requirements in DoD

4160.21-M, Defense Materiel Disposition Manual. This HWMP will help ensure that Robins

AFB is in compliance with all local, state, and federal regulations. All organizations and persons at Robins AFB and tenant organizations off-site (i.e. Robins AFB/Central Georgia Technical

College Avondale Road Annex) who handle or perform other actions involving hazardous waste shall comply with this HWMP.

The FFCA states that all federal installations must comply with all federal regulations and that these regulations are to be enforced by those states that have authorization from EPA. The state of Georgia Department of Natural Resources (GA DNR) Environmental Protection Division

(EPD) has authorization to inspect Robins AFB, issue notices of violations, and levy monetary penalties. Federal employees can be held criminally and civilly liable for the violation of the federal regulations governing hazardous waste management. This plan sets forth procedures for the proper management of HWs to avoid notices of violation, subsequent penalties, and possible criminal charges. This plan outlines procedures for the management of HW from the point of generation to accumulation, on base transportation, and storage at the 90-day accumulation sites.

Security Instructions

The long title of this document is Robins AFB Hazardous Waste Management Plan. The short title is Robins AFB HWMP.

Figures 5 and 6 in this document is CONTROLLED UNCLASSIFIED INFORMATION and does not fall within the scope of directives governing the protection of classified information.

Although UNCLASSIFIED, those figures are FOR OFFICIAL USE ONLY. Handle and destroy in accordance with DoDM 5200.01 Vol. 4, and Air Force Records Information Management

System.

Disseminate information contained herein only to those agencies and personnel whose official duties specifically require knowledge of the plan, including those required to develop supporting plans. Do not reproduce this document without permission except as stated above.

This plan supersedes the Robins AFB HWMP, dated September 2013.

2.0 INSTALLATION PROFILE

Installation Profile

Scope of Plan This HWMP applies to all organizations and persons at

Robins AFB who handle or perform other actions involving hazardous waste, and compliance with the provisions set forth in this HWMP is required. This includes Robins

AFB/Central Georgia Technical College Avondale Road

Annex.

Office of Primary Responsibility

(OPR)

78 CEG/CEIER has overall responsibility for implementing the HWMP and is the lead organization for monitoring compliance with applicable federal, state and local regulations

HW Program Manager Contact 78 CEG/CEIER

Alternate HW Program Manager N/A

Emergency contacts 9-1-1 or 478-222-2900

NOTE – When dialing 9-1-1 from a cell phone the caller must immediately identify they are reporting an emergency for Robins AFB. Houston County 9-1-1 Center will transfer the call to the RAFB Emergency Communication Center.

Refer to Appendix A for additional contact information

Waste registration numbers EPA I.D. GA1570024330

HW generator status Large quantity generator

Universal waste handler status Large quantity generator

Permitted HW operations Building 352 and Building 359

Federal or FGS regulatory references 40 CFR 260-265

State and local regulatory agencies Georgia Department of Natural Resources, Environmental

Protection Division

State and local regulatory references GA 391-3-11 – Hazardous Waste Management

Approved HW disposal contractors Distribution Logistics Agency(DLA)

HW accumulation sites Refer to Appendix B and C

HW accumulation time limits 90, 365 days

HW generator reporting frequency Biennial

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

The AF environmental program adheres to the Environmental Management System (EMS) framework and its Plan, Do, Check, Act cycle for ensuring mission success. Executive Order (EO) 13693, Planning for Federal Sustainability in the Next Decade, U.S. Department of Defense Instruction (DoDI) 4715.17, Environmental Management Systems, AFMAN 32-1065, Environmental Management, and international standard, ISO 14001:2004, provide guidance on how environmental programs should be established, implemented, and maintained to operate under the EMS framework.

The HW management program employs EMS-based processes to achieve compliance with all legal obligations and current policy drivers, effectively managing associated risks, and installing a culture of continuous improvement. The HWMP serves as an administrative operational control that defines compliance-related activities and processes.

4.0 GENERAL ROLES AND RESPONSIBILITIES

The major roles/organizations involved in supporting the HW management program include:

Wing/Installation Commander

ESOHC

HW Manager/Alternate

Shop/HW Generator Personnel

Initial Accumulation Point (IAP) and Hazardous Waste Accumulation Site (HWAS)

Supervisors/Managers

Unit Commanders

Unit Environmental Coordinators (UECs), see AFMAN 32-1065 for role description

Contracting Officer

Defense Logistics Agency Disposition Services

Tenant Organizations

AFCEC

Detailed information about typical responsibilities for these and other roles is available in the HW

Playbook. Additional HW management-related roles and responsibilities are described throughout this plan and in referenced documents.

Installation Supplement – General Roles and Responsibilities

This plan is applicable to all HW generating and management activities at Robins AFB including petroleum, oil, and lubricant (POL) storage areas, Initial Accumulation Points (IAPs), Hazardous waste

Accumulation Areas (HWASs), and Treatment, Storage, and Disposal Facilities (TSDFs).

HW management requires the full involvement of product directorates and organizations on the base, including contractors and tenants. Liability associated with mismanagement of HW, coupled with the rising costs of management and disposal requires a management approach that transcends the normal chain of command. The Environmental Management Branch, 78 CEG/CEIER, is the Office of Primary

Responsibility (OPR) for HW management. Other organizations provide compliance oversight, analytical support, and other types of services in support of the Robins AFB HWMP. The Installation Commander is ultimately responsible for all aspects of the installation’s solid and hazardous waste management programs. Generating activities, both host and tenant, bear the responsibility for ensuring HW management functions are in full compliance with this plan.

Tasked agencies and individuals will be responsible for publishing such procedures as necessary for the operation and execution of this plan. In addition, Generating Activity Commanders/Deputy Commanders will appoint a HW Primary Manager and at least one HW Alternate Manager for all shops that generate

HW. Commanders can delegate appointment authority to Flight Chiefs and shop superintendents. A shop is allowed and encouraged to have more than one HW Alternate Manager. These individuals will be responsible for properly accumulating waste, labeling and marking containers, and performing the actual turn-in of wastes to the EHWAS or Hazardous Waste Processing Facility (HWPF) and will represent their organization during inspections. Care must be taken to ensure that HW Primary and/or Alternate

Managers on extended temporary duty are back filled as necessary to ensure each shop has a manager available. These managers shall be available for recall during their non-duty hours to deal with HW issues that may arise. The following information shall be provided to the Environmental Management

Sustainment Section (78 CEG/CEIER) within 7 days of any change:

Name, rank/grade, duty phone number, building number, and office symbol of primary and alternate waste managers.

Name of shop and building number where wastes are accumulated and stored.

Types and quantities of all waste generated (be specific).

Installation Commander (78 ABW/CC)

The Installation Commander will:

Be ultimately responsible for all aspects of the installation’s HW management programs.

Installation Commander will ensure that management of HW on Robins AFB complies with applicable portions of 40 Code of Federal Regulations (CFR) Parts 260-280 and Georgia State

Hazardous Waste Management Regulations.

Sign memorandum implementing this HWMP.

Sign all installation HW permit applications as required; this authority shall not be delegated.

Ensure that a HWMP is current, available, and followed by installation personnel.

Ensure the proper disposal of all wastes from the installation.

Ensure that the legal office and Civil Engineer coordinate on any permits, land use restrictions, or other binding agreements with the regulatory agencies.

Environmental Management Branch (78 CEG/CEIE)

78 CEG/CEIE will:

Manage the Environmental Management program.

Sign hazardous waste reports.

Delegated signature authority by the installation commander to sign and certify regulatory reports and hazardous waste manifests.

Environmental Management Sustainment and Restoration Section (78 CEG/ CEIER)

78 CEG/CEIER will:

Operate and maintain the HWPF located at Building 359.

Provide container labels (Appendix D), Robins AFB Hazardous Waste Labels, and containers to generating activities. Maintain computerized tracking system for all HW containers on Robins

AFB from issue through disposal (as applicable).

Submit an annual certification of waste profiles to DLA Disposition Services.

Receive waste from IAPs, IHWAS’s, and EHWASs.

Sample contents of containers and transport samples to Robins AFB Science and Engineering

Laboratory (802 MXSS/MXDTD) for analysis or send to a contract lab if necessary.

Prepare and complete Hazardous Waste Profile Sheets with support from the waste generator and

DLA Disposition Services.

Use DLA Disposition Services as the HW disposal agent for routinely generated HW.

Perform HW management compliance inspections of Robins AFB and Robins AFB/Central

Georgia Technical College Avondale Road Annex.

Assist waste-generating activities in HW identification, waste management, waste storage, and disposal. Serve as OPR for establishment/closure of IAPs and HWASs.

Certify funds are available for HW disposal.

Maintain an inventory of commonly used empty containers that meet the DOT specifications.

Pickup properly packaged and labeled HW and Universal Waste (UW) batteries from EHWASs

(and IAPs/IHWASs where an EHWAS is not available) upon request and transport to Building

359.

Weigh containers prior to funds certification.

Manage the HWM program.

Coordinate reporting of potential violations and spills with 78 ABW/JA.

Complete the Biennial Waste Report and coordinate the report with 78 ABW/JA.

Prepare HW reports and compliance documentation as required by EPA, the state regulatory agency, and Air Force instructions. Provide and maintain copies of required reports including the

Biennial Waste Reports and Exception Reports (when waste is transported to a TSDF directly from CEIE) to Georgia EPD.

Maintain records of HW management inspections of Robins AFB and Robins AFB/Central

Georgia Technical College Avondale Road Annex.

Coordinate with federal, state, county, and city authorities on HW management procedures.

Serve as OPR for maintaining and operating the Hazardous Waste Facility Permit (HWFP) for

Robins AFB.

Provide all applicable records to representatives of Georgia EPD or EPA who are duly designated by the Administrator.

Maintain routine liaison with Headquarters (HQ) Air Force Materiel Command (AFMC), EPA, and state regulatory agency in regard to HW inspections, rule interpretation, and problem resolution.

Sign manifests for HW.

Assist generators with asbestos management and disposal issues.

Update and maintain the Hazardous Waste Training Plan and determine hazardous waste training requirements.

Environmental Management Compliance Section (78 CEG/CEIEC)

78 CEG/CEIEC will:

Manage disposal of HW from past HW disposal/release sites.

Coordinate disposal of hazardous waste from restoration sites through 78 CEG/CEIER.

Maintain a copy of manifests and disposal certificates from removal/disposal of HWs from sites remedied through private contractors. DLA Disposition Services will maintain original manifests and disposal certificates for HW disposed of through them.

Act as an alternate emergency response coordinator.

Manage the Environmental Impact Analysis Process (EIAP). Maintain documents generated from environmental assessments resulting from the impact of HW management operations.

NOTE: This data may contain critical information that may need to be protected (from an OPSEC perspective). Consult your unit OPSEC Program Coordinator (OPC) for guidance.

Update EESOH-MIS data

78th Medical Group Bioenvironmental Engineering Flight (78 MDG/SGPB)

78 OMRS/SGPB will:

Provide industrial hygiene/occupational health consulting services.

Provide information on Safety Data Sheets (SDSs).

Provide guidance on the management and disposal of radioactive mixed waste.

Assist in development and maintenance of the base’s waste stream inventory by providing access to available data in Bioenvironmental Engineering Flight (BEF) case files. NOTE: This data may contain critical information that may need to be protected (from an OPSEC perspective). Consult your unit OPSEC Program Coordinator (OPC) for guidance.

Advise workers on personal protective equipment to be worn by workshop personnel potentially exposed to a HW stream.

Ensure all Personal Protective Equipment (PPE) is on the current Approved PPE List.

Participate in HW exercises, if requested by 78 CEG/CEIE.

Advise 78 CEG/CEIE, when requested by 78 CEG/CEIE, on exposure of waste products relating to personnel health and safety.

Public Affairs Office (78 ABW/PA)

78 ABW/PA will:

Act as the focal point for inquiries from the news media and concerned citizens regarding HW, including HW incidents. NOTE: This data may contain critical information that may need to be protected (from an OPSEC perspective). Consult your unit OPSEC Program Coordinator (OPC) for guidance.

Assist the Installation Commander during situations involving HW incidents by keeping interested news media and the public aware of events and curtailing rumors through the dissemination of coordinated, accurate information.

Respond to the accident/incident site, to the Command Post, and to the Public Affairs duty section where an information center may be established.

Maintain applicable security and safety provisions (although the presence of HW in a contained area will probably not constitute reasonable cause to forcibly deny access to the area by accredited news media representatives, under no circumstances will the Public Affairs Office personnel escort news media representatives into a hazardous or potentially dangerous area).

Supervisors of HWAS/IAP Managers/Alternates

Supervisors of HWAS/IAP Managers/Alternates will:

Be familiar with the duties of HW HWAS/IAP site managers and alternates.

Be able to obtain an accurate listing of waste streams and HWAS/IAPs within the work area from the Enterprise Environmental, Safety, and Occupational Health Management Information System

(EESOH-MIS), the HAZMAT cell, a pharmacy, or a Unit Environmental Coordinator (UEC).

Contact the UEC immediately for changes in HWAS/IAPs or waste streams.

Attend annual HW training provided by UECs.

Appoint HWAS/IAP managers and alternates for each work shift.

Ensure subordinates performance plans and position descriptions reflect their HW management duties.

Ensure subordinates attend appropriate HW management training before working with HW, and annually thereafter. Ensure training is site specific and documented for regulatory inspection.

Review all weekly inspection checklists completed by the HWAS/IAP managers/alternates.

Verify discrepancies have been corrected.

Immediately inform the UEC of any discrepancy that cannot be corrected on the spot.

Contact UEC for questions about HW management.

Verify each IAP has a sign posted above the container clearly designating the collecting point and

IAP management requirements. IAPs in an office environment (e.g. Building 645), “one-time” collection containers, or containers in an open area with no structure available for sign placement are not required to be placarded.

Commanders/Directors of Units that Generate HW

Commanders/Directors of Units that generate HW will:

Provide adequate and safe equipment and locations for HWAS/IAPs.

Ensure the management of HW HWASs/IAPs comply with federal and state HW management regulations and this HWMP.

Appoint a primary and alternate HW manager for each shop that generates HW. Commanders can delegate appointment authority to Flight Chiefs and shop superintendents. Provide a list containing the name, rank/grade, duty phone number, building number, and office symbol of all primary and alternate waste managers to 78 CEG/CEIER. The list will be updated as often as necessary to ensure accuracy. A copy of updated lists will be provided to 78 CEG/CEIER within

7 days of any change.

Ensure supervisors of shops are familiar with HW management procedures. The HW manager will retain overall responsibility for the management of the HWAS/IAPs at all times.

Allow appropriate facilities, shops, and equipment to be inspected for HW management regulatory compliance by 78 CEG/CEIER and authorized state or federal inspectors.

Ensure all personnel who handle HW or who are otherwise involved in HW management receive required training.

Ensure all discrepancies found during an internal or external inspection are corrected promptly.

Air Force Installation Tenants

All Air Force Installation Tenants will:

Comply with the installation HW management program and applicable environmental laws unless exempted by DoD/AF instruction. When a tenant is in non-compliance with HW laws, the

Installation Commander has the authority to take whatever action is necessary to require tenants to comply. Installations will ensure through memorandums of understanding or other appropriate means that their tenants:

o Meet the appropriate tenant responsibilities as spelled out in installation waste management plans.

o Conduct their activities IAW the installation’s permit requirements. Non-DoD tenants should apply for their own EPA identification number when possible.

o Submit reports required by the installation’s HWMP within time frames established.

o Reimburse the installation for waste disposal costs of AFMAN 65-605, Volume 1, Budget

Guidance and Technical Procedures. A tenant who has not been exempted must reimburse the installation for its accumulated charges exceeding $125 for any calendar quarter. Billings that do not exceed $125 for any calendar quarter must also be paid unless they are waived by the installation.

o Reimburse the installation for fines and penalties that the Installation Commander determines are attributable to their activities.

HW HWAS Managers

HWAS Managers will:

Comply with HWMP Installation Supplement – Accumulation Area Management.

Ensure the HWAS complies with federal, state, and local regulations and requirements of this

HWMP.

Assume overall responsibility for management of the HWAS.

Coordinate with 78 CEG/CEIER, 778 CEG/CEXF, 78 OMRS/SGPB, and Ground Safety on location of the HWAS.

Maintain all applicable HW documentation and correspondence in the Recordkeeping and

Reporting section. NOTE: This data may contain critical information that may need to be protected (from an OPSEC perspective). Consult your unit OPSEC Program Coordinator (OPC) for guidance.

HW IAP Managers

IAP Managers will:

Comply with HWMP Installation Supplement – Accumulation Area Management.

Ensure IAPs comply with federal, state, and local regulations and requirements of this HWMP.

Assume overall responsibility for management of the IAP.

Coordinate with the UEC and 78 CEG/CEIER on location of an IAP.

Maintain all applicable HW documentation and correspondence listed in Recordkeeping and

Reporting section. NOTE: This data may contain critical information that may need to be protected (from an OPSEC perspective). Consult your unit OPSEC Program Coordinator (OPC) for guidance.

Ensure waste placed in container is associated with a specific, nearby process. Only those approved wastes routinely added to the container from a nearby process are permitted.

Waste Generating/Managing Organizations

Waste Generating/Managing Organizations will:

Ensure HW management activities are conducted in accordance with this HWMP and all federal, state, and local requirements.

Appoint a primary and alternate UEC to act as points-of-contact (POC) for issues concerning HW management. Provide copy of appointment letter to 78 CEG/CEIER. Provide notice of any changes to these appointments to 78 CEG/CEIER within 7 days of the change.

Ensure coordinators and alternates receive annual HW training. Ensure supervisors of UEC maintain training records for the UEC and alternate.

Conduct periodic surveys of facilities to ensure processes generating HW have been identified.

Maintain a list of HW streams currently generated within organizational facilities.

Notify 78 CEG/CEIER of any newly identified, or changed, HW generating process within 7 days of discovery. NOTE: This data may contain critical information that may need to be protected (from an OPSEC perspective). Consult your unit OPSEC Program Coordinator (OPC) for guidance.

Take active measures to reduce the volume of HW generated within each respective organization.

Ensure organizational personnel involved with management of HW receive annual HW management training provided by their UEC.

Allocate annual funding for HW disposal.

UECs

UECs will:

Represent their organization on matters concerning HW management. Those organizations with separate divisions performing HW functions may appoint one UEC per division.

Attend HW training on an annual basis. Training requirements and sources are outlined in

Section 5.0, Training.

Coordinate HW management training for unit personnel who handle or who may be otherwise involved in the management of HW, including HWAS/IAP managers and alternates and their supervisors.

Conduct reviews of waste stream inventory. Submit an accurate HW inventory to 78

CEG/CEIER upon discovery of updated information within 7 days of discovery.

Be responsible for requesting waste determination on any items in their product directorate/organization with unknown storage/labeling/disposal procedures.

Be responsible for immediately notifying 78 CEG/CEIER when the generator determines the need for a waste determination.

Review operating instructions prepared by their organization on HW management procedures.

Serve as the organization’s coordinator for disseminating information and providing generation activities with guidance on characterization, segregation, packaging, and labeling of HW. Serve as POC for disseminating information on HW turn-in procedures and disposal guidance.

Coordinate and expedite the gathering of information and coordinate with 78 CEG/CEIER concerning waste stream generation within the organization/directorate.

Provide changes to existing waste streams and information on new waste streams to 78

CEG/CEIER as soon as the UEC is made aware of them by the generating activities. Act as representative for evaluating and obtaining necessary process information and appropriate samples for items requiring waste determination and/or storage/labeling/disposal guidance.

Inspect all of the organization’s HW IAPs, HWAS as needed to maintain compliance.

Ensure the organization’s IAP inventory is accurate. Immediately report changes in the existing

IAP inventory to 78 CEG/CEIER. Ensure proper information is forwarded to 78 CEG/CEIER to establish a new IAP.

Communicate directly with the organization’s Director/Commander on issues pertaining to HW management.

Verify that each IAP has a sign (Appendix D) placed above the collection point clearly designating the point’s location. IAPs in an office environment (e.g. Building 645), “one-time” collection containers, or containers in an area with no structure available for sign placement are not required to be placarded.

Provide assistance/advice to supervisors and HW managers/alternates on appropriate type container for accumulating and storing waste, appropriate procedures and methods for transportation of HW from IAP(s) or HWASs, and establishing IAPs and HWASs in coordination with 78 CEG/CEIER.

Elevate to the appropriate management level any discrepancies found during inspections that cannot be fixed on the spot for assistance in resolution as required.

Ensure information in EESOH-MIS for all HW activities under each UECs control is accurate and up to date. Access to EESOH-MIS will be provided by 78 CEG/CEIER.

DLA Disposition Services

DLA Disposition Services will:

Maintain a current copy of the installation’s HWMP.

Dispose of hazardous property and HW by reutilization, resale, or service contract.

Maintain all HW documentation and correspondence for a minimum of 3 years. Maintain land disposal notices and certifications for a minimum of 5 years.

Conduct and document HW management training for all DLA Disposition Services personnel.

Maintain personnel training records at the DLA Disposition Services office. The records shall be available for inspection by state, federal, and 78 CEG/CEIER inspectors.

Ensure compliance with the HWFP.

Provide guidance on requirements for turn-in and disposal of HW and materials.

Advise generators and CEIEC of any changes in Department of Defense (DoD) turn- in document procedures or in packaging, marking, and labeling requirements.

Dispose of HW in accordance with federal, state, USAF, DoD, and DLA policies.

Monitor contractual and regulatory compliance of HW disposal contractors administered through

DLA Disposition Services.

Confirm each HW shipment reaches the disposal site safely, and the disposal site receives the shipment described on the manifest. Complete an Exception Report when necessary (see Section

6.0 Recordkeeping and Reporting) and maintain a copy of the report for at least 3 years.

Appoint a representative to the EPC.

Science and Engineering Laboratory (802 MXSS/MXDTD)

802 MXSS/MXDTD will:

Provide analytical support as required for characterization of HW.

Ensure analyses are performed in accordance with applicable federal and state requirements.

Maintain waste analysis reports performed by 802 MXSS/MXDTD for a minimum of 3 years.

Provide 78 CEG/CEIER with a copy of all waste analysis reports.

Provide guidance to 78 CEG/CEIER when requested on the appropriate procedures to follow to profile a waste based on existing analytical data, process knowledge, or chemical data from

SDSs. Upon request by 78 CEG/CEIER, review completed profiles for accuracy of analytical/chemical data.

Safety Office (78 ABW/SE)

78 ABW/SE:

Inspect HW HWASs during the regular annual ground safety inspection. All safety items will be inspected and made part of the formal inspection report. NOTE: Formal Inspection reports data may contain critical information that may need to be protected (from an OPSEC perspective).

Consult your unit OPSEC Program Coordinator (OPC) for guidance.

Assist units in ensuring that the handling and storage of all HW is in accordance with applicable federal regulations, Air Force safety regulations, and technical orders.

Participate in HW training when requested.

Contracting Directorate (AFSC/PK)

The Contracting Directorate will:

Brief contractors on compliance with any prohibitions on storage and disposal of toxic and HMs.

Ensure federal, state, local, and DoD environmental requirements for work to be completed on-base are addressed in all contracts.

Take action if contractors are not complying with requirements set forth in Statements of Work or other related documents.

Fire Protection Branch (778 CEG/CEFX)

778 CEG/CEFX will:

Provide technical assistance and advice concerning fire prevention and fire protection necessary at all HW areas.

Inspect IAPs and HWASs on a periodic basis to ensure compliance with USAF and National Fire

Protection Association standards.

Serve as a member of the ESOHC.

Participate in HW training efforts when requested by 78 CEG/CEIER.

Staff Judge Advocate (JA)

78 ABW/JA will:

Provide legal counsel to the Installation Commander and CE on all enforcement actions, notices of violation, permit issues, and all other legal issues arising from handling of hazardous or regulated waste under the requirement of law.

Be provided timely copies by 78 CEG/CEIE of documentation and correspondence from regulatory authorities or as between the installation and these authorities.

Provide legal counsel and other legal support in connection with hearings regarding the above issues.

Provide legal counsel regarding HW regulatory requirements.

Provide 78 CEG/CEIER legal with counsel concerning generation, storage, disposal, and manifesting of HW.

Provide legal counsel to 78 CEG/CEIE on new regulations and requirements.

Provide legal counsel and coordination on correspondence sent to the EPD or EPA or other regulatory entity on HW management issues.

Provide representation for Robins AFB in negotiations with regulatory authorities and attorneys for private parties, and in administrative litigation arising from Robins AFB’s HW management activities.

Provide legal review and legal counsel regarding contracts submitted by 78 CEG/CEIE pertaining to HW disposal and other management.

Provide legal counsel and participation in rulemaking by EPA/EPD and other regulatory authority pertaining to Robins AFB HW management.

Provide legal counsel and liaison between Robins AFB and the U.S. Attorney’s Office in any litigation in which the U.S. Attorney is, or might be, representing Robins AFB regarding HW and related activities.

Provide legal counsel, representation, liaison, and coordination with Regional Counsel and

AFMC/ELO (AFLOA/FSC Environmental Liaison Officer) regarding negotiations with Federal, State, or local government representatives concerning enforcement actions or other compliance matters.

Provide legal counsel, representation, liaison, and forward request from Robins AFB to

AFLOA/JACE regarding consent orders, compliance orders, and other such proposed agreements with Federal, State, or local government representatives, and provide that no such agreement will be entered into with provision for payment of any penalty or similar payment provision (such as

Supplemental Environmental Projects), without prior approval of AFLOA/JACE.

Be provided timely notice by 78 CEG/CEIE of spills, releases, discharges, etc., and provide coordination and legal counsel. NOTE: This type of data may contain critical information that may need to be protected (from an OPSEC perspective). Consult your unit OPSEC Program Coordinator (OPC) for guidance.

5.0 TRAINING

HW awareness training is provided to satisfy regulatory requirements and needs. All personnel whose work involves HW, and their immediate supervisors, must successfully complete HW training appropriate to their job responsibilities. Until the employee has received the appropriate HW training, the employee may only handle HW under the supervision of a trained individual. HW training is provided by authorized personnel. Training records are maintained IAW the Recordkeeping and Reporting section of this plan.

Installation Supplement – Training

Initial and annual refresher training is required by EPA/Georgia DNR (Title 40 CFR 265.16 and 40 CFR

264.16) for all personnel working in permitted waste management facilities and HWASs. Training for

Initial Accumulation Point (IAP) personnel is not required by EPA/Georgia DNR regulations but is required by AFMAN 32-7002. Each Unit Environmental Coordinator (UEC) is responsible for ensuring proper training and proper documentation of training required for hazardous waste management activities is achieved for their respective unit at Robins AFB. 78 CEG/CEIER is responsible for maintaining the environmental training plan which outlines base wide training requirements. The training consists of instructions covering a basic overview of RCRA; Robins AFB HW accumulation, turn-in, and disposal procedures; and emergency response procedures. A list of the required training for each level is included in Appendix D, Training Requirements Matrix. The facility/shop supervisor, UEC, and Unit Commander are responsible for ensuring that training and documentation requirements are met at the required levels.

The HW worker’s supervisor is responsible for documenting training and what level of specific training categories were met.

HW management training is required for all personnel whose jobs entail handling, monitoring, and disposing of HW at facilities that fit into the following categories:

Permitted HW storage facilities.

HWASs or IAPs.

Emergency response organizations that may respond to HW incidents.

Production organizations that must dispose of HM/HW.

Personnel associated with the following organizations shall receive HW management training:

78 CEG/CEIE personnel that manage or handle HW.

DLA Disposition Services personnel that manage or handle HW.

All Product Directorates and Tenant Organizations that generate HW including but not limited to:

o HWAS Managers.

o Supervisors of HWAS Managers.

o IAP Managers/Alternates.

o Supervisors of facilities with IAPs.

o Other workers who handle HW.

Federal regulations for training personnel managing HW (40 CFR 264.14) list the following requirements for classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility’s regulatory requirements:

Training must be directed by a person trained in HW management procedures and must include instruction which teaches facility personnel HW management procedures (including contingency plan implementation if applicable) relevant to the positions in which they are employed.

At a minimum, the training must be designed to ensure facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including, where applicable:

o Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment.

o Key parameters for automatic waste feed cut-off systems.

o Communications or alarm systems.

o Response to fires or explosions.

o Shutdown of operations.

Facility personnel must successfully complete the previously listed training within 3 months after the effective date of employment or assignment to a facility, or to a new position at a facility, whichever is later. Employees must not work in unsupervised positions until they have completed the required training.

Facility personnel must take part in annual training (at least once every 365 days).

The supervisor must maintain the following training documents and records at the facility:

o The job title for each position at the facility related to hazardous waste management, and the name of the employee filling the job.

o The job description for each employee. This description must include the requisite skill, education, or other qualifications, and duties of employees assigned to each position.

o A description of the type and amount of introductory and continuing training given to each employee.

o Records that document the training of each employee as required.

Training records on current personnel must be maintained while the employee is performing work at the facility. Training records for former employees must be maintained for at least 3 years from the date the employee last worked at the facility. The EHWAS, IHWAS, and Roll-off On-

Site Recordkeeping Coversheet in Appendix D can be used as a guide to ensure the proper records are maintained.

The Air Force requires the following subject matter to be covered in training:

Introduction to RCRA.

Identification of HWs.

Accumulation point management.

Container use, marking, labeling, and on base transportation.

Waste turn-in procedures.

Manifesting and transportation of HW.

Spill prevention and response to emergencies.

Waste reduction.

Recordkeeping and pollution prevention (required by RCRA).

Personnel health and safety and fire safety.

The HW training program at Robins AFB includes facility-specific training courses developed by organizations to supplement and complement the HWMP.

Robins AFB requires that all new personnel must complete the required training prior to performing tasks involving handling or management of HW. Personnel who have not received the required training will not be allowed to perform any tasks involving HW unless they are supervised by trained personnel.

Additionally, annual refresher training is required. Robins AFB also requires all supervisors of personnel performing HW management activities must receive OSHA HW Supervisor/Management training (29

CFR 1910.120) before they can supervise HW operations at permitted facilities. This training is required, unless the employer can demonstrate the operation does not involve employee exposure or the reasonable possibility for employee exposure to safety or health hazards. Contact 78 ABW/SE for additional information.

Levels of Training. In addition to the required elements of training, Robins AFB requires the following categories of training provided to the appropriate personnel involved in hazardous waste management:

Level 1 - Training provides the trainee with expert proficiency to perform HW decision making duties. It includes in-depth descriptions of all requirements under RCRA, any state-specific regulations, and the installation HWMP for that training element. Category 1 training allows the trainee the ability to use their knowledge to ensure installation HW activities, policies, and procedures are in compliance with all such requirements. Environmental Management personnel, UECs, Accumulation Site managers, and supervisors of hazardous waste generating processes (as needed depending on the recommendation from the UEC) receive Category 1 training. UEC’s who have received Category 1 training can provide Category 1 or 2 training to unit personnel.

This training level is typically provided in a classroom environment but can be computer-based.

Level 2 - Training provides the trainee with a general awareness of compliance requirements under RCRA and the installation's HWMP. Training of general awareness allows the trainee to know the very specific technical requirements for the management of HW generated at the installation. Failure to follow these requirements could result in monetary penalties against the installation and possible criminal action against the individuals. The general awareness course covers at least the general requirements of RCRA cradle-to grave management, including a brief description of the elements set for the above including how to handle spill reporting. Employees in work centers generating HW will receive Category 2 training. UEC’s who have received

Category 1 training can provide Category 2 training to unit personnel.

Sources of Level 1 Training

Level 1 (Expert). Primary method of accomplishing Level 1 training is through the Employee

Information Management Center (EIMC) training portal or The Environmental Awareness

Course Hub (TEACH). This training consists of a PowerPoint presentation and test. Contact your Unit Training Manager or UEC to register for this course. The employee MUST complete this course to be Level 1 qualified. Take other courses as a substitute only if access to the EIMC course is restricted. Access EIMC at https://eimc.robins.af.mil/EIMC_Portal/EIMC.cfm. Access

TEACH at https://usaf.learningbuilder.com.

RCRA Hazardous Waste course (MRXSCI0000200SU) is a 4-hour class that will also meet the requirements for Level 1 training. Contact your Unit Training Manager to schedule this training through the Training Scheduling System (TSS) or the Education and Training Management

System (ETMS).

The Air Force Institute of Technology offers a Hazardous Waste Management Course (WENV

521) that will also meet the requirements for Level 1. This 5-day satellite broadcast course is at http://www.afit.edu/CE/

UEC’s who have received Level 1 training can provide Level 1 training to unit personnel.

Sources of Level 2 Training

Level 2 (General Awareness). Primary method of accomplishing Level 2 training is through the

EIMC training portal or TEACH. This training consists of a PowerPoint presentation and test.

Contact your Unit Training Manager or UEC for enrollment in this course. The employee MUST complete this course to be Level 2 qualified. Take other courses as a substitute only if access to the EIMC course is restricted. Access EIMC at https://eimc.robins.af.mil/EIMC_Portal/EIMC.cfm https://usaf.learningbuilder.com/ https://eimc.robins.af.mil/EIMC_Portal/EIMC.cfm. Access TEACH at https://usaf.learningbuilder.com.

The Air Force Institute of Technology offers a Hazardous Waste Accumulation Seminar (WESS

010) that will also meet the requirements for Level 2 training. This 2-hour internet course is at http://www.afit.edu/CE/.

UEC’s who have received Level 1 training can provide Level 2 training to their unit personnel.

Personnel involved with HW management tasks include, but are not limited to:

o Generators, supervisors, and managers.

o UECs, HWAS Managers, and IAP Managers.

o HWPF personnel.

o Spill response personnel.

o Base transporters.

o Laboratory chemists.

o Employees of permitted units.

o HW disposal contract monitors.

Some tasks being performed by the above personnel include, but are not limited to:

Deciding which wastes are HW.

Completing HW manifests, annual reports or exception reports.

Adding HW into accumulation containers or tanks at HWASs.

Removing HW from accumulation tanks or containers.

Transporting waste to or from storage and treatment units and to disposal facilities.

Transporting HW to or from HWASs.

Performing HW cleanup (non-emergency response).

Inspecting HW HWASs, storage, treatment, or disposal facilities.

Operating HWASs, and IAPs.

Working at permitted or interim status TSDF.

Collecting HW samples.

Conducting other HW related activities as designated by base.

Training documentation

Proper documentation of HW training is required. Supervisors of employees receiving HW training are responsible for ensuring their records are updated and maintained. The records must include, as a minimum, the records listed in Section 6 of this plan and previous training related to

HW management, date training was received, instructor name, and projected date of refresher training. Each shop shall maintain these records in their environmental files or EMIC system.

Input and tracking in the EIMC system is the required method for Air Force organizations.

Tracking systems used by other agencies must provide the same tracking capability and records content of EIMC. These systems must be approved by 78 CEG/CEIER prior to use

6.0 RECORDKEEPING AND REPORTING

Recordkeeping

The installation complies with the following U.S. Federal HW recordkeeping requirements.

https://eimc.robins.af.mil/EIMC_Portal/EIMC.cfm https://usaf.learningbuilder.com/

Summary of HW Recordkeeping Requirements

Record* Retention Time** Citation

HW determination documentation

3 years from the date that the waste was last sent to a TSDF

40 CFR 262.40

HW Biennial/Annual Report 3 years from the due date of the report 40 CFR 262.41

HW manifest 3 years from the day the waste was accepted by the initial transporter

40 CFR 262.40

HWAS inspection logs 3 years from the date the inspection was conducted

40 CFR 262.15

40 CFR 265.15 (d)

40 CFR 265.174

Exception reports 3 years from the due date of the report 40 CFR 262.42

Land restricted waste determination

3 years from date the determination was required to be conducted. If not required, 3 years from the date the waste was last sent to a TSDF

40 CFR 268.7

Land restriction notice and certification

3 years from the date the waste was last sent to a TSDF

40 CFR 268.7

Notification of intent to export waste

3 years from the date the HW was accepted by the initial transporter

40 CFR 262.53

EPA acknowledgement of consent (for exports)

3 years from the date the HW was accepted by the initial transporter

40 CFR 262.51

40 CFR 262.53

Waste export confirmation of delivery

3 years from the date the HW was accepted by the initial transporter

40 CFR 262.54

Annual report (required of primary exporters of HW)

3 years from the date the HW was accepted by the initial transporter

40 CFR 262.56

Employee training records

(including appointment letters for key HW personnel)

Current personnel: until closure of the site;

Former personnel: 3 years from date the individual last worked there

40 CFR 262.15

40 CFR 264.16

*Permitted Treatment, Storage and Disposal Facilities (TSDF) comply with recordkeeping requirements established in their HW permit.

**Retention Time may be extended during the course of any unresolved enforcement action or as requested by the U.S. Environmental Protection Agency (EPA). The AF, through the Air Force Records Information

Management System (AFRIMS), requires that HW-related reports, documents, studies, HW manifests, and disposal records (including contracts) are destroyed 50 years from the date of the record.

NOTE: These types of records may contain critical information that may need to be protected (from an

OPSEC perspective). Consult your unit OPSEC Program Coordinator (OPC) for guidance.

Reporting

The HW Manager, and other designated personnel, generates needed reports from EESOH-MIS.

Enforcement actions, spills, and inspections are reported via the Enforcement Actions, Spills, and

Inspections (EASI) database.

Installation Supplement – Recordkeeping and Reporting

Recordkeeping

Each HW management function will maintain files and records necessary to comply with Georgia DNR requirements.