8.9 NAVSEA Guide to Environmental Compliance Requirements.pdf

GUIDE TO

ENVIRONMENTAL COMPLIANCE

REQUIREMENTS

FOR

CONTRACTORS AND

SUBCONTRACTORS

Online document is the master. Printed copy is an uncontrolled copy Document Control Point: Environmental Code 1023

KEYPORT CONTRACTOR GUIDE

OCTOBER 2019

Environmental Compliance Requirements for Contractors and Subcontractors

Revision Status

REVISION ISSUE DATE BRIEF DESCRIPTION OF CHANGE

NR 30 JAN 18 Initial Release

1 16 OCT 19 Revised, updated, and clarified guidance. Revised manual to make it consistent with Naval Base Kitsap (NBK) guidance and practices.

ABOUT THIS GUIDE

Compliance with all applicable Federal, State, local laws, and Department of Navy environmental requirements is mandatory. This Contractor’s Guide is provided to help assist contractor’s with complying with Environmental requirements while working on base.

This guide is intended to provide general guidance for contractors working within the Naval Base Kitsap (NBK) Keyport installation, and is sometimes referred to in the document for simplicity sake as the “base” or “Keyport”. Where the guide references the “Base Environmental Office (BEO)” the document is referring to the Points-of-Contact listed in the guide’s BEO telephone listing. These points of contact may be NAVFAC or NUWC Division Keyport personnel depending upon internal Navy roles and responsibilities and host-tenant command support agreements. All contractor BEO coordination should be coordinated through the contracting officer’s representative and/or contracting officer.

This document is for guidance and training purposes only. It remains the contractor’s duty to comply with all applicable laws, regulations, and local requirements and this guide alone cannot assure such compliance. To the extent, the guidance contained in this document conflicts with contract specifications, the contract specifications are the controlling document. If the contractor believes this guidance conflicts with contract specifications, these concerns shall be addressed with the Contracting Officer and/or Contracting Officer’s Representative (COR).

EMERGENCY RESPONSE INFORMATION WHILE

WORKING ON BASE

When an emergency happens (Medical Assistance, Fire, Flooding, Spill Response, etc.)

minutes matter and valuable time can be lost if searching for an emergency contact or location information.

IMPORTANT: There are different numbers to call at Keyport depending upon what phone system you are calling from.

Personal/Company Mobile, or Non-Navy Phones

When using a personal or company supplied mobile phone or a non-Navy phone call:

Navy Regional Dispatch Center:

- Emergency Phone: (360) 396-4444

- Non-Emergency Phone: (360) 315-4064

NOTE: All 911 calls made on Navy property from mobile phones or non-Navy phones are routed to Kitsap County Central Command (CENCOM), which must then relay your information to the Navy Regional Dispatch Center. This is an unnecessary additional step, which could delay response.

Navy Phones

When using a Navy phone on a Navy exchange call:

Navy Regional Dispatch Center:

- Emergency Phone: 911

- Non-Emergency Phone: 5-4064

NUWC Division, Keyport Duty Office Only:

- Non-Emergency: 6-2244

Critical information the dispatcher needs to know:

WHAT BASE ARE YOU CALLING FROM? NBK Keyport WHERE IS THE EMERGENCY? Give the address, nearest cross street, and include building number, spelling out, e.g.; Building One-Zero-Five-Zero, instead of Building Ten-Fifty.

WHAT'S THE EMERGENCY? Medical, Hazardous Material (HAZMAT) Spill, Explosive incident, Fire (Smell of smoke, etc.)

WHO NEEDS HELP? Age, gender and number of people.

Once you have relayed the information, the dispatcher will verify it so don’t hang up yet!

Remain calm and give direct answers to the questions asked. Speak slowly and clearly.

The dispatcher will ask additional questions so they can send the right type of help. All questions are important. The dispatcher may also provide you with CRITICAL PRE- ARRIVAL INSTRUCTIONS, so listen carefully. Lastly, ensure someone with knowledge of the emergency is standing by at the building entrance or street corner to flag down responding units and escort them to the scene.

BEO TELEPHONE LISTING

Below are designated points of contact for various Environmental program areas.

These individuals may provide information and guidance, but are not authorized to provide direction to contractors. Only the Contracting Officer is authorized to make final determinations on appropriate actions. For general Environmental compliance information related to projects, the Environmental Project Coordinator will be the primary Environmental office point of contact, and should be able to direct any questions to the appropriate program manager or subject matter expert.

EMERGENCIES (Medical Assistance, Fire, Flooding, Emergency Spill Response, etc.):

When using a (personal) telephone/mobile (360) 396-4444 When using a Keyport (government) telephone

ENVIRONMENTAL PROJECT COORDINATOR (NUWC KEYPORT) .... (360) 315-8571

ENVIRONMENTAL PROJECT COORDINATOR (NBK) .......................... (360) 396-5879

ENVIRONMENTAL DIRECTOR (NAVAL BASE KITSAP) ....................... (360) 315-5411 ENVIRONMENTAL MANAGER (NUWC KEYPORT) ............................... (360) 396-5682

ENVIRONMENTAL POINT OF CONTACT

Air Discharges and Ozone Depleting Substances .................................... (360) 396-5878 Asbestos Management ............................................................................. (360) 315-3833 Hazardous Material Management ........................................................... (360) 396-5438 Hazardous (Dangerous) Waste Management ......................................... (360) 396-2320 Installation Restoration (Contaminated Superfund Sites) ........................ (360) 396-0060 Solid Waste Management ....................................................................... (360) 396-7005 Spill Prevention and Response Planning ................................................ (360) 315-8571 Spill Prevention and Response (SPCC) and Tanks (UST’s & AST’s) ..... (360) 315-2451 Storm water .............................................................................................. (360) 315-1992 Water Quality, Sewer/Wastewater Discharge .......................................... (360) 315-8571 Forestry ..................................................................................................... (360)-396-0064

ENVIRONMENTAL SERVICES:

Hazardous Waste Services (Labels, Drums, Pickups,etc.) (360) 396-7992Hazardous Waste Services Email: KYPT_TSDFHazardousWaste@navy.mil Hazardous Waste Designation ................................................................ (360) 396-7991

TABLE OF CONTENTS ______________________Page

Contents

ABOUT THIS GUIDE

EMERGENCY RESPONSE INFORMATION WHILE WORKING ON BASE

Personal/Company Mobile, or Non-Navy Phones

Navy Phones

Navy Regional Dispatch Center:

NUWC Division, Keyport Duty Office Only:

TELEPHONE LISTING

INTRODUCTION

ENVIRONMENTAL COMPLIANCE

ENVIRONMENTAL TRAINING

SPILL PREVENTION AND RESPONSE

Storage Tanks and Oil Filled Equipment

Preventative Measures

Required Training for Petroleum Transfers

SPILL EVENTS

NON-EMERGENCY SPILL EVENT

EMERGENCY SPILL EVENT

HAZARDOUS MATERIAL MANAGEMENT

Hazardous Material Management and Approval

Restricted Hazardous Materials

WASTE MANAGEMENT

HAZARDOUS (DANGEROUS) WASTE MANAGEMENT

Training

Waste Determination (Designation)

Waste Sampling

Waste Containers

Waste Labeling

Waste Accumulation Areas

Waste Pickup, Shipment, and Disposal

SOLID (NON-HAZARDOUS) WASTE MANAGEMENT

RECYCLING

POLYCHLORINATED BIPHENYLS (PCBs)

CLEAN WATER

Drinking Water

Stormwater

Stormwater Pollution Prevention Plan

Pressure Washing

Wastewater and Sanitary Sewer Discharges

CLEAN AIR

Refrigerants and Ozone Depleting Substances (ODS)

Air Contaminant Generating Processes and Equipment (including Control Equipment)

Temporary Portable Non road Engines for Projects

Common Clean Air Act Concerns for Projects

ASBESTOS

DEMOLITION

Site Approvals and Environmental Considerations during Demolition Projects

Clean Air and Asbestos Considerations for Demolition Projects

CONTAMINATED SITES

EXCAVATIONS

Soil Handling Procedures

Site Approval and Environmental Considerations

NATURAL RESOURCES

Forestry

CULTURAL RESOURCES

APPENDIX A- EXAMPLE FORMS

Note- Forms listed in Appendix A are Examples provided for training and background and are not maintained up to date. Current up-to-date versions of Submittal forms should be obtained from the Project Manager and/or BEO

1. CHMI

2. WGR

3. Site Registration Form

4. Waste Disposal Request Form

APPENDIX B

APPENDIX C

INTRODUCTION

The Navy is committed to being a good environmental steward; operating in a manner compatible with the environment and in compliance with environmental regulations. The NUWC Division, Keyport’s Environmental Policy proclaims the Navy will operate in an environmentally responsible manner while performing its mission, and any company under contract with the Navy, must also provide a personal commitment to environmental protection.

ENVIRONMENTAL POLICY

It is the Environmental Policy of the NUWC Division, Keyport that we are committed to:

- Conducting business in an environmentally responsible manner that promotes pollution prevention, resource conservation, and environmental stewardship.

- Operating our processes in compliance with applicable legal requirements and with other requirements that relate to our environmental aspects.

- Continually improving our workplace to reduce environmental risk.

- Developing annual targets to serve as guidance for planning and operations.

- Ensuring this policy is communicated to all persons working for or on our behalf and is available to the public.

This commitment is important regardless of whether your job is large or small. Whether you are involved in a major construction project or a small paint job, it is mandatory to consider the environment in all of your operations. Your awareness and participation are vital to the success of the Navy’s mission and our ability to comply with the various environmental laws.

To support the Navy’s Environmental policy, all contractor’s working at Keyport should be knowledgeable of:

NUWC Division, Keyport’s Environmental Policy (included above), Potential environmental impacts/aspects associated with their work, and Emergency response procedures while working on base.

Environmental regulations continue to evolve and change. Keyport operates under separate discharge permits for air emissions, wastewater/sewer discharges, and stormwater discharges. Specific to hazardous waste, Keyport operates as a large quantity generator. Compliance with environmental regulations requires specialized knowledge and expertise. The Base Environmental Office (BEO) will provide information that will help in understanding environmental compliance responsibilities while working on base.

ENVIRONMENTAL COMPLIANCE

“Environmental compliance” means conforming to all applicable environmental laws/regulations including site-specific permits and program requirements. The cost of environmental compliance is a legal responsibility. Non-compliance is far more costly over time as consequences of serious violations can include individual penalties and civil/criminal charges as well as bad publicity, which will affect relations with the community as well as the ability to receive new contracts. Contractors must always include environmental compliance in their policies, procedures, and operations.

Large projects such as construction projects will have environmental controls specified in the contract. The contract will specify if a formal Environmental Protection Plan must be submitted to the Contracting Officer for review and comment (a generic Environmental Protection Plan template is available upon request). If this requirement is not specified in the contract, a meeting with members of the Base Environmental Office (BEO) is recommended and may be required by the contract prior to starting the job to ensure that the contractor has an adequate understanding of all applicable requirements and site specific considerations for working at Keyport.

All contractors and contractor personnel are required to comply with all applicable federal, state, and local environmental laws and regulations applicable to the work they are performing at all times. It is incumbent upon the contractor to know, understand, and follow all relevant rules and regulations pertaining to protection of the environment while performing work for which they are contracted.

Additionally, there may be project and site specific considerations to ensure compliance with environmental rules and regulations while performing work in conjunction with the government at Keyport.

Potentially significant environmental considerations for working at Keyport, depending upon the specific work to be performed, includes but is not limited to:

Knowing the Emergency response numbers and procedures at Keyport.

Hazardous Material (HM) approval and management procedures for use of HM at Keyport.

How to properly manage and dispose of solid waste, recyclable waste, and

Hazardous waste on base Your requirements, roles, and responsibilities for specific environmental impacts known to be applicable to the work being performed.

Understanding your responsibilities related to existing government permits applicable to the work being performed.

If it is not clear how these considerations should be addressed during your project, you should request clarification from your COR.

ENVIRONMENTAL TRAINING

In addition to compliance with all applicable federal, state, and local environmental laws and regulations, all contractors and contractor personnel are required to comply with applicable certification and training requirements related to the work performed.

Depending upon the work being performed, Navy instructions and existing facility permits may require that contract employees receive additional site specific environmental compliance training prior to beginning work onsite. This Contractor’s Guide is provided to help assist contractor’s with complying with Environmental requirements while working on base.

Keyport has developed general environmental awareness training for personnel working onsite, which is designed to meet all site specific awareness level environmental training requirements for working on-base. Awareness training specifically satisfies personnel awareness level training requirements for Emergency Response, NUWC Division, Keyport’s Environmental Management System (EMS), stormwater pollution prevention, Hazardous Waste (HW) management, and base environmental protection programs.

Additionally, groups that generate and manage Hazardous Waste (HW) at Keyport are required to appoint a HW Site Manager and HW Site Manager Alternate. HW Site Managers and Alternates receive more detailed training on HW management procedures and requirements while working on base than general awareness level training.

Site specific government provided training does not relieve the contractor from knowing and complying with all federal, state, and local training and certification requirements necessary in order to perform the duties specified in the contract.

Site specific government provided environmental training is available from the BEO in person and electronically and should be scheduled through the project COR.

SPILL PREVENTION AND RESPONSE

To ensure protection of Washington waters, land, air, and natural resources from the impacts of Oil and Hazardous Substance (OHS) spills, you must operate in a manner that will provide the best protection for the environment. Implementing the following procedures will help reduce the risk of a spill occurring and minimize the potential impacts if a spill does occur.

Storage Tanks and Oil Filled Equipment

Keyport has many Above Ground Tanks (ASTs), transformers, generators, and oil filled operational equipment. Due to the quantity of oil in storage at Keyport, an Oil Spill Prevention Control and Countermeasure (SPCC) Plan is required to meet the Environmental Protection Agency (EPA) regulations of 40 CFR 112. The purpose of the SPCC Plan is to describe the general operating design/procedures that affect the facility’s potential for the discharge of oil products (which includes oil in any form) and to document measures taken to prevent discharges of oil into waters of the United States. It also describes procedural, structural and equipment improvements, and/or upgrades that must be implemented to satisfy the requirements of 40 CFR 112 for over water transfer of oil.

Oil in any form in containers of 55 gallons or larger is subject to the regulations of 40 CFR 112 (know as the “SPCC Rule”). Any new oil containers of 55 gallons or larger brought on base must be listed in the Keyport SPCC plan and follow the SPCC Rule. Any repair, change in location, or alteration to any Underground Storage Tank (UST), Above ground Storage Tank (AST), oil container, or oil filled operational equipment must be reported to the BEO so it can be documented in the SPCC plan and to ensure that there are adequate spill containment controls in place. Any new USTs or changes to existing USTs or their ancillary systems must also be in accordance with federal, state, and local requirements and reported to the BEO.

Additional information regarding Oil and Hazardous Substance (OHS) storage and OHS storage tanks, may be obtained from the BEO via the COR.

Preventative Measures

All OHS Handling and transfer equipment shall be inspected prior to use and during operation to ensure equipment is in proper working condition. All connections and transfer points shall be carefully checked prior to, during, and after transfer operations to monitor for leaks. Hose connections shall be wrapped and/or containment placed under them. All storm drains near the transfer location shall be covered with temporary storm drain mats.

All OHS shall be carefully controlled and all OHS liquid storage areas must be properly managed. Areas that can impact the stormwater system must have discharge control structures (e.g., curb, sumps, secondary containments, or other types of spill prevention) to contain potential spills, leaks, and discharges. Storage of OHS containers in uncovered secondary containment locations must have provisions for sampling of, controlled draining of, and proper disposal of stormwater that accumulates in the containment area. You, as a contractor, are responsible for storing your OHS only in authorized areas and in an authorized manner.

Keyport will respond to all spills, but contractors must provide a spill response kit and discharge control devices for any handling and transferring operation involving OHS. The kit needs to contain items appropriate for the clean up of the type of spill that could occur. If you have any questions concerning this requirement, contact the COR and the BEO.

Required Training for Petroleum Transfers

The Washington Department of Ecology requires that all personnel involved in bulk petroleum handling operations are certified. Certification is accomplished by successful completion of a training course in Oil Spill Prevention and Response. Key supervisory and operations personnel must have a certification that meets the requirements of WAC 173-180C.

Key operations personnel are identified as employees with direct involvement in the transfer, storage, handling, or monitoring of oil (e.g., person-in-charge, storage tank operators, or oil transfer monitors). Key supervisory personnel must directly supervise the transfer, storage, handling, or monitoring. Before conducting any OHS transfer at Keyport, you are responsible for ensuring your personnel are trained to the State and facility specific requirements before starting the operation. Over-water OHS transfers are subject to additional requirements and must be coordinated with the BEO.

Additional help or clarification on the required training for certification may be obtained from the BEO via the COR

SPILL EVENTS

A spill event involves the unauthorized spilling, leaking, pumping, emitting, emptying, discharging, injecting, escaping, leaching, disposing, or dumping of oil or a hazardous substance. Spill events are categorized as non-emergency or emergency. All spill events, regardless of whether they are classified as an emergency or non-emergency spill event, must be reported by dialing (360) 396-4444.

NON-EMERGENCY SPILL EVENT

A non-emergency spill event is a discharge of a known material or any hazardous substance that can be cleaned up as part of normal housekeeping by the personnel who discovered the spill. The spill does not pose an immediate threat to human health or the environment and is not released on the soil, into any waterway inlet (e.g., storm drain), or outside Keyport’s boundaries.

Actions Required

Stop the source of the spill.

Call 360-396-4444 and report the event.

Contain the spilled material by keeping the spill away from drains or waterways and by blocking off drains located near the spill if the spill may reach them.

Clean up the spilled material wearing the proper personal protective equipment.

Dispose of the spill debris properly (see Waste Management sections of the guide).

EMERGENCY SPILL EVENT

An emergency spill event is any release of a known or unknown material or hazardous substance that poses an immediate threat to human health or the environment. In these situations, the individual that discovers the spilled material must immediately dial (360) 396-4444 to report the incident. All unpermitted or uncontrolled releases on land, or discharged to any waterways or outside base properties, are classified as emergency spill events.

Actions Required

Immediately take action as appropriate to contain or stop the source of the spill if this action can be taken without jeopardizing the health or safety of yourself or other people.

If the properties of the material are unknown or they are a threat to human health, evacuate the area and go upwind.

Immediately dial (360) 396-4444 and provide the requested information.

Warn others in the area and direct them upwind.

Make yourself available to emergency response personnel.

Provide Safety Data Sheets (SDS) for the spilled material to the emergency response personnel Notify the Contracting Officer.

HAZARDOUS MATERIAL MANAGEMENT

“Hazardous Material (HM)” is defined as any material that, because of its quantity, concentration, or physical, chemical, or infectious characteristics, may pose a substantial hazard to human health or the environment.

The procurement, storage, use, and minimization of HM’s at Keyport requires control and management measures to protect the user and environment from potential or actual hazards. All HM’s to be brought onsite, must be reviewed and approved by the BEO.

To ensure employee safety, plan for effective emergency response, and to ensure compliance with facility Emergency Planning and Community Right-to-Know reporting requirements, contractors are required to provide Safety Data Sheets for all Hazardous Material they bring onto the base, and provide information regarding the amount and type of HM they will be using and storing while performing contract work on base.

Hazardous Material Management and Approval

All HM brought onto Keyport by contractors must be labeled clearly as “Contractor Owned Material” and reported to the BEO. This requirement is accomplished by contractor pre-labeling material prior to bringing the material onsite, and by submission of Safety Data sheets (SDS’s) and the Contractor’s Hazardous Material Inventory Form

(CHMI).

Provide a Safety Data Sheet (SDS) for each HM to that will be used and stored on base during the performance of the contract along with the quantity (to include type and size of containers) that will be brought on base, where and how it will be used, and how many days it will be on base. HM’s include, but are not limited to, hazardous gases, liquids, powders, or solids, such as acids, alkalis, bases, caustics, cleaners, coatings, coolants, corrosives, cryogenics, degreasers, finishes, epoxies, flammables, fluxes, inks, lubricants, oils, paints, sealants, solders, solvents, strippers, toners, thinners, varnishes, and waxes.

An example CHMI form is included in Appendix A of this guide.

If additional HM’s are needed as work progresses, submit SDS’s for new material along with a revised CHMI that includes information for the new material. Contractors are responsible for ensuring that while on base, their HM is stored safely and in compliance with applicable federal, state, and local regulations so that the material does not become an employee safety, fire, or spill risk. Contractors shall also ensure their employees are apprised of material hazards per the Occupational Safety and Health Administration (OSHA) Hazard Communication (HAZCOM) standard. This standard states that employees have the “Right-to-Know” about hazardous materials in their workplace. Any personnel working with hazardous material should have hazard training in accordance with the HAZCOM standard.

All unused or partially used HM that is brought on base by the contractor for the performance of their work is the property of the contractor and shall not be left at the facility or turned in to the government for disposal as Hazardous Waste upon completion of work.

Quick Tip: Plan jobs to ensure processes or operations use the least hazardous option and minimum quantity necessary for the job. This saves costs and reduces waste. Ensure that all HM is clearly labeled as “Contractor Owned Material” while onsite, and ensure that SDS’s are submitted and an up to date CHMI form is maintained for all of your on-site HM that will be used as part of the contract. Upon completion of the project, remove all unused/partially used HM from the site.

CONTRACTOR HAZARDOUS MATERIAL INVENTORY form (CHMI)

Figure 1 – Contractor Hazardous Material Inventory (CHMI) – [See Appendix A]

Restricted Hazardous Materials

Certain chemicals contained in HM’s are prohibited for use on base without a viable and compelling technical need and the use of HM’s containing some chemicals are restricted due to specific safety and environmental risks associated with the chemicals.

Example of potentially prohibited or restricted chemicals include but are not limited to:

leads, chromiums, mercury, phenols, trichloroethylene, halons, PCBs, asbestos, silica sand (for use as blasting agent), Class I Ozone Depleting Substances (ODS) within Heating, Ventilation, & Air Conditioning System (HVAC) or fire suppression systems, radioactive materials or instruments capable of producing ionizing radiation, and chemicals listed in 40 CFR 355.50, Appendix A. The Contracting Officer may consider exceptions to the use of any of the above excluded materials upon written request by the Contractor, and with BEO approval via the COR

Restricted materials will require special controls for use, and may not be used in a manner such that the vapors, fumes, aerosols, or other mobile hazards could potentially reach unprotected work areas or thoroughfares.

WASTE MANAGEMENT

The composition and estimated quantity of each waste expected to be produced as part of your project should be identified. For larger projects, this information is typically included within the project Specifications.

Each waste that will be produced must be categorized as Hazardous (HW), Refuse (R), or Recyclable Material (RM). A waste is considered hazardous if it meets certain levels of reactivity, ignitability, corrosively, or toxicity, or is otherwise listed as a hazardous waste. The State of Washington regulates more waste as hazardous than mandated by Federal Law, and has adopted the term “dangerous waste” to include Federal hazardous waste and State regulated waste.

Proper waste management coordination is not only needed for compliance, it also benefits projects by preventing time delays or operational shutdowns and improves public relations. Therefore, it is always beneficial to maintain a proactive approach to ensure that waste is handled properly, and disposed of in a timely manner.

HAZARDOUS (DANGEROUS) WASTE MANAGEMENT

The Keyport facility is regulated as a large quantity generator of Hazardous Waste (HW).

All HW generated onsite must be designated at the point of generation, and managed in accordance with NUWC Division, Keyport’s dangerous waste management plan and procedures and WAC 173-303 requirements for large quantity generators.

Keyport uses the terms hazardous waste and dangerous waste interchangeably, so use of the term hazardous waste in this guide includes all waste regulated by Washington State.

Hazardous waste management and compliance with HW management requirements is a responsibility which must be planned for and accepted as a cost of doing business with the government.

HW Management Training

Projects which generate and manage HW at Keyport are required to appoint a HW Site Manager and HW Site Manager Alternate. The HW Site Manager and Alternate receive detailed site specific training on HW management procedures and requirements for working on base and are responsible for interfacing with the BEO to ensure HW management requirements are satisfied throughout the duration of the project.

NUWC Division, Keyport HW Site Manager/Alternate training is provided by the BEO and may be conducted in-person or electronically, contractors should contact their COR for scheduling HW Site Manager/Alternate training.

Waste Determination (Designation)

Waste Designation is the process of determining whether a waste meets the requirements of a Hazardous (Dangerous) Waste. All waste, not just the waste that is known to be dangerous or hazardous, is required to be designated at the point of generation, to ensure proper storage and management of the waste. Hazardous waste is required to be managed properly and accounted for from the point where the waste is generated (cradle) to the point where it is finally disposed of and determined to no longer be hazardous (grave).

As the owner of the facility, and owner of the facility’s Environmental Protection Agency (EPA) Waste ID#, the Navy is responsible for determining whether waste generated at the facility meets the requirements of hazardous (dangerous) waste.

Designation of waste at Keyport is performed by the BEO, and is documented using the Waste Generation Record (WGR) form. The project HW Site Manager/Alternate submits a WGR form to the BEO for each waste stream that will be generated while working on-base as part of the contract.

In some cases, it may not be known whether a waste is a HW until testing can be conducted to verify the waste’s dangerous characteristics. In such cases, the waste containers shall be put into separate secondary containment, based on the type of waste contained, and labeled as “Waste Awaiting Designation (WAD)” along with the most probable waste hazards, if known (for example flammable liquid/solid, corrosive, toxic, etc.). WAD containers, shall be managed as HW and labeled with known or reasonably expected hazards, until determined otherwise, but should be physically segregated from containers of known designated HW.

The project HW Site Manager/Alternate will be expected to fill out the WGR form to the best of their knowledge and provide any information requested in order for the government to properly and accurately designate the waste.

WASTE GENERATION RECORD (WGR)

Figure 2 – Waste Generation Record (WGR) – [See Appendix A]

Waste Sampling

At times, it is necessary to sample and analyze waste to determine whether the waste meets the definition of hazardous waste. The BEO will determine the required analysis necessary in order to properly and accurately designate waste. The contract will specify whether sampling and analysis services for hazardous waste designation is the responsibility of the contractor or the government.

Typically, sampling and laboratory analysis for waste designation for projects is conducted by the BEO. If waste designation sampling and analysis will be conducted by the BEO, you will need to coordinate with the COR to partner with BEO personnel to obtain a representative sample(s) of project waste streams.

If the contractor is to provide sampling and analysis services for waste designation as part of the contract, contract sampling personnel must be trained and proficient in required environmental sampling techniques and procedures and contract laboratories must meet applicable accreditation standards for the analysis being conducted.

If you will be providing sampling and analysis services as part of the project, sampling personnel qualifications and laboratory, accreditation should be included within the project’s contract submittals.

Waste Containers

HW generated during work on base must be stored in appropriate containers immediately at the point where the waste is produced. Projects must have proper containers on-hand to contain hazardous waste, BEFORE any hazardous waste is produced.

General tips and guidelines for container management:

Maintain containers closed at all times, except when waste is being added or removed. Containers with liquids must be closed and secured with ring and bolt, or bung screwed in (wrench tight) and provided with secondary containment that will contain 100% of the single largest container present and at least 25% of all containers. Containers with solids must have snug fitting lids. Containers containing volatile organic compounds, must meet appropriate requirements for adequately containing vapors.

No items except waste specifically designated for the container may be placed in the container.

Only re-use containers for the same waste stream.

All containers must be appropriately labeled (see labeling) and positioned so that the labels are clearly visible. Place the labels on the side of the upper one-third of the drum whenever possible. When using roll-off boxes, place labels on the door of the container.

Maintain a minimum of 30 inches of aisle space between each row of containers, so that all containers can be readily inspected and material handling and emergency response personnel can access all containers.

The contract will specify who is responsible for supplying containers for storing HW while working on base. If the contract does not specify or is unclear, immediately notify the COR.

If it is your responsibility to provide hazardous waste containers, ensure the containers used meet all federal, state, and local requirements for storage and transportation of the waste that will be stored in it. It is also recommended that consideration be given to optimizing the size of the containers for ease of handling, transport, and management.

If it is the government’s responsibility to provide HW containers for the project, containers will be supplied by the BEO. Contact the BEO through the COR to schedule container pickup/delivery.

Hazardous Waste Services (Labels, Drums, Pickups,etc.) (360) 396-7992 Hazardous Waste Services Email: KYPT_TSDFHazardousWaste@navy.mil

Waste Labeling

All containers containing HW must be labeled appropriately in accordance with federal, state, and local environmental regulations.

The BEO will supply the appropriate waste labels (i.e., HW,WAD, and DOT) for waste produced by projects at Keyport. Empty containers shall be labeled clearly as “Empty”.

Contact the BEO to schedule label pickup/delivery.

Hazardous Waste Services (Labels, Drums, Pickups,etc.) (360) 396-7992 Hazardous Waste Services Email: KYPT_TSDFHazardousWaste@navy.mil

Waste Accumulation Areas

Project HW is required to be controlled properly at the point of generation. All project HW must be stored at the project site in accordance with the waste accumulation requirements for large quantity generators. Contractor waste accumulation areas must meet Satellite Accumulation Area (SAA) and <90 day accumulation area requirements, contained in WAC 173-303, as applicable. Keyport is required to maintain an up to date record of all HW accumulation areas located on base, along with information regarding the types and quantities of HW stored in those areas to ensure effective emergency management planning.

General tips and guidelines for establishing and managing Waste Accumulation Areas:

Locate project SAA’s and <90 day areas in order to minimize the potential impact of spills. Pick a site that minimizes weather impact. If possible, avoid siting accumulation areas over the water or upslope from the water or a storm drain.

Consider the use of curbing or storm drain protectors to minimize the impact of potential spills.

Ensure fire extinguishers are available and emergency response signage is adequately posted.

Accumulation start dates must be accurately maintained. Waste from SAA’s must be transported to a <90 day site or to the Building 1051 TSD within 72 hrs of filling the waste container. Waste from <90 day sites must be transported offsite or to the Building 1051 TSD within 90 days of the waste being generated.

Ensure Accumulation areas are used only for the storage of HW and waste awaiting designation (WAD). Do not store HM, materials, or other equipment within project waste accumulation areas.

All Project Accumulation areas must have appropriate signage. Signs reading “HAZARDOUS WASTE ACCUMULATION AREA” and “DANGER - UNAUTHORIZED PERSONNEL KEEP OUT” must be posted at the entrance to the accumulation area and legible from a minimum distance of 25 feet.

“NO SMOKING OR OPEN FLAME” signs should be posted on all visible sides of the accumulation area and be legible from 50 feet.

The HW Site Manager and/or Alternate must perform weekly documented self-inspections of accumulation areas.

The BEO will conduct periodic inspections of facility accumulation areas and the HW Site Manager/Alternate and the COR will be notified if any deficiencies are identified.

During the duration of the project, the HW Site Manager/Alternate should maintain a weekly logbook of their self-inspections and document any findings and corrective actions implemented. The COR and BEO should be notified of any significant findings of non-compliance.

When the project is complete, prior to closure of any accumulation area(s), any and all containers, liners, signage, or material must be removed from the site and the site returned to its original condition.

The BEO will inspect project HW accumulation areas prior to establishment and disestablishment. Arrange for establishment and disestablishment of project Satellite Accumulation Area’s (SAA’s) and < 90 day areas by contacting the BEO and using the “Site Registration Form”. An example “Site Registration Form” is included in Appendix A.

Hazardous Waste Services (Labels, Drums, Pickups,etc.) (360) 396-7992 Hazardous Waste Services Email: KYPT_TSDFHazardousWaste@navy.mil

SITE REGISTRATION FORM

Figure 3 – Site Registration Form– [See Appendix A]

Waste Pickup, Shipment, and Disposal

HW generated at Keyport is required to be managed under NUWC Division, Keyport’s HW management program, and shipped and disposed of under Keyport’s site EPA ID#.

NUWC Division, Keyport owns and operates a permitted Treatment, Storage, and Disposal (TSD) Facility on base, where HW may be safely stored, consolidated, and sometimes treated onsite. The permit for NUWC Division, Keyport’s TSD facility allows for safe storage of HW at the site for a period of time of up to one year.

Arrange for waste pickup and/or shipment for disposal with the BEO prior to project waste meeting accumulation area storage time limits. The majority of project non-bulk waste will be arranged for pickup by the BEO and consolidated and stored at the onsite TSD facility prior to eventual shipment offsite for disposal. In some instances, it may be advantageous to ship waste directly to an offsite receiving facility from the project site.

In either instance, the government will determine waste shipment requirements and must maintain documentation related to the HW being shipped, the HW receiving facility, and the means by which the waste was ultimately disposed of by the receiving facilities.

The contract will specify whether HW disposal costs are the responsibility of the government or the contractor. Regardless of who is responsible for waste disposal costs, no HW may be shipped offsite without the authorization and documentation of the

BEO, and the BEO signing the HW shipment manifest.

The BEO will determine appropriate waste pickup/shipment/disposal requirements for all HW. Waste pickup and disposal requirements at Keyport are documented on the Waste Disposal Request (WDR) form. An example WDR form is included in Appendix A. Contact the COR to schedule waste pickup/shipment/disposal through the BEO.

Figure 4 – Waste Disposal Request (WDR) – [See Appendix A]

SOLID (NON-HAZARDOUS) WASTE MANAGEMENT

The term “solid waste” is used to describe designated waste that is not “HW”, “PCB”, “Universal Waste”, or “Asbestos”. This term can include construction debris, liquids, and landfill controlled waste. Remember that all waste must be designated prior to removal from Keyport.

Solid waste shall be reported to the COR as required by contract submittals. The waste material must be identified along with whether it was reused, recycled, or disposed of, its solid waste tracking sheet (SWTS) serial number, its load numbers, and its weight. In addition, include government provided Waste Determination documentation that the waste was not HW (WDR).

Control and Management

Place solid waste in approved and labeled containers so that it is not stored on the ground.

If recycling is an option for a waste stream, (e.g., asphalt, concrete, cardboard, scrap metals, and unpainted, untreated wood) keep it free from other types of waste.

Keep solid waste accumulation area along with the surrounding area clean and free of debris.

Liquids are not allowed in the dumpster or at the landfill. Containerize and recycle or dispose of them in accordance with applicable requirements.

Disposition

Be sure to empty containers no less than once per week unless the COR has approved a different schedule. Vehicles and haulers used for the transportation of solid waste shall be permitted, licensed, or otherwise approved, by the applicable County Health District(s).

Ensure waste is not taken to any site that has not been approved by the COR prior to removal from the work site and contractors must be sure their drivers take the waste to a location the contractors specified to the government.

Contractors are responsible to ensure no disposal action is taken which could be construed as illegal dumping.

A cover must be in place over the waste while it is being transported

RECYCLING

Waste Minimization is one of Keyport’s top priorities. Recycling is one tool to help reduce the quantity of waste produced on base.

The contract will specify responsibilities and procedures for recyclable waste produced while working on base. If the contract does not specify or is unclear, immediately notify the COR.

It is important to note that in many instances where the Navy does not provide recycling services, the Navy may require monthly reports of what was recycled and what was wasted (land filed or disposed of as hazardous) within project contract submittals. If a Monthly Project Waste Summary Report (CMPWSR) is required by your contract, fill out the CMPWSR each month and turn the information in to the COR. If you have questions or concerns regarding recycling for your project, please request clarification from the

COR.

Regulations vary on how waste must be managed prior to recycling, depending on the waste itself. The most common categories for recycling are:

(1) Specifically regulated recyclable materials. These are recyclable materials regulated under their own respective sections of Washington State Administrative Code (WAC) 173-303 (e.g., spent lead-acid batteries).

(2) Recyclable materials that are not regulated. These are materials that are not regulated prior to use or reuse (e.g. cardboard or paper).

(3) Recyclable materials that are fully regulated. These materials are fully regulated up to the point when they actually enter the recycling process that recycles the material (e.g. Chloroflurocarbons (CFC) and anti-freeze).

Oftentimes, waste that is destined for recycling must still be controlled and managed as HW until the point at which the waste is reclaimed.

Kitsap County Public Works Solid Waste Division is an excellent resource for local recycling options and can provide guidance and information regarding Recycling resources within Kitsap County.

http://recycle.kitsapgov.com/Pages/Home.aspx

POLYCHLORINATED BIPHENYLS (PCBs)

Since 1979, the Environmental Protection Agency regulates the use, storage, disposal, and distribution in commerce of PCBs. The law for PCBs is the Toxic Substance Control Act (TSCA). Common equipment containing PCB’s includes electrical transformers and fluorescent light ballasts.

Light ballasts may or may not contain PCBs. If they are not labeled "No PCB" then they are assumed to contain greater than 50 parts per million (ppm) PCB and are regulated under the TSCA. Transformers should be labeled identifying their PCB content.

Discarded transformers, capacitors, or bushings containing PCBs at concentrations of 2 ppm or greater (except when drained of all free-flowing liquid) are regulated in Washington state as HW. Fluid, core, and core papers from these specific sources are also regulated in Washington as a HW when generated from the salvaging, rebuilding, or discarding of transformers, capacitors, or bushings.

Samples are required for materials that have been shown in the past to contain PCBs above the regulatory limit of 50 ppm. See Waste Management section for information on management requirements for PCB containing waste.

CLEAN WATER

Drinking Water

Obtain a connection permit from the Naval Base Kitsap Public Works Department prior to making any connections or changes to the potable drinking water system. A connection permit is necessary even for small or temporary connections (e.g. connecting an ice machine, temporary connection to a fire hydrant, etc.).

Call (360) 396-4060 to obtain a permit.

Backflow Preventer need/size/type will be determined by the base water shop; only the water shop is authorized to make this decision.

If making significant system changes (system extension, system improvement, capacity change, etc.) permission from the Department of Health may be required.

Contact the COR immediately if significant water system changes may be required.

Decommissioned wells or geotechnical borings drilled for a project shall be in accordance with MINIMUM STANDARDS FOR CONSTRUCTION AND

MAINTENANCE OF WELLS (WAC 173-160).

Stormwater

The purpose of storm drains is to prevent flooding by conveying stormwater runoff to saltwater or stormwater facilities. All discharges going directly into surface waters such as Liberty Bay, Hood Canal, or streams and wetlands are strictly controlled and no contaminants are authorized. Examples of prohibited discharges include all hazardous materials and wastes, petroleum products, solvents, detergents, wastewater, and contaminated ground water. Industrial wastewaters cannot be disposed of as stormwater and must be disposed of in accordance with hazardous waste regulations. Get approval for projects disturbing more than one acre before discharging any water anywhere!

Information you will need to know about your project regarding stormwater control:

Will there be any ground disturbing activity? Make sure to include not only the footprint of the project, but also staging areas, temporary trailers, parking, retention ponds, etc.

Will there be total ground disturbance greater than 1 acre?

Does the slope exceed 35% at any point within the project or will any work within the footprint take place on known unstable soils?

Will there be groundwater dewatering for foundations or other construction activity?

Will any hazardous material, waste, demolition debris, soil, open or leaky dumpsters, or any other potential pollutant be exposed to stormwater?

Is this a major renovation or construction project (> $5 million if renovation, >

$750K if construction)? If yes, “Low Impact Development” (LID) must be considered in the design, or justification must be provided if LID is not utilized.

Does the project add 2000 square feet or more of new impervious surface, convert 3/4 acre or more of native vegetation to landscaped area, or have land disturbing activities of 7000 square feet or more? If yes, have the 10 minimum requirements listed in Volume I of the Stormwater Management Manual for Western Washington been evaluated for applicability, and has a hydrologic analysis been conducted.

Does the analysis indicate a requirement for flow control and/or runoff treatment structures? Are these structures included in the project footprint?

Which water body will receive the project stormwater?

Stormwater Pollution Prevention Plan

Sites disturbing 1 Acre or More A Stormwater Pollution Prevention Plan (SWPPP) must be completed by the Contractor and be approved by the COR prior to beginning construction activities. The SWPPP shall be prepared in accordance with the requirements outlined in the latest version of the Stormwater Management Manual for Western Washington, which can be found at the following link.

http://www.ecy.wa.gov/programs/wq/stormwater/manual.html

The SWPPP must be completed and approved prior to submitting the Notice of Intent (NOI) to EPA for the construction project. The NOI must be approved by EPA prior to commencing construction activities. Upon completion of construction, submit a Notice of Termination (NOT) to the EPA.

Sites disturbing under 1 Acre When a site covers less than one acre, a SWPPP, NOI, and NOT are unnecessary;

instead, the contractor is required to submit a brief statement and receive approval by the BEO regarding adequate controls prior to construction activity. This statement shall include:

Brief project description.

Total acreage disturbed.

Project supervisor and other points of contact.

Project drainage information.

Sequence of construction.

Stormwater Best Management Practices (BMPs) that will be…