Atch 34-APPENDIX 32 Installation Plan 12 - Hazardous Waste Management Plan (27 Sep 23).pdf

HAZARDOUS WASTE MANAGEMENT PLAN

U. S. AIR FORCE

Installation (Nellis and NTTR) Plan 12

DEPARTMENT OF THE AIR FORCE

HEADQUARTERS 99TH AIR BASE WING (ACC)

NELLIS AIR FORCE BASE NEVADA

27 September 2023

MEMORANDUM FOR DISTRIBUTION

FROM: 99 ABW/CC

SUBJECT: Nellis AFB and NTTR Plan 12, Hazardous Waste Management Plan

References: (a) AFMAN 32-7002, Environmental Compliance and Pollution Prevention

(b) Resource Conservative and Recovery Act (RCRA)

1. The Nellis and NTTR Plan 12 is designed to assist in managing Hazardous Waste and fulfills requirements established by AFMAN 32-7002 and applicable state and local statutes. Included are procedures necessary to comply with hazardous waste management provisions of the RCRA. This plan is effective upon receipt and supersedes Nellis and NTTR Plan 12, dated 1 July 2015.

2. Plan revision action is due no later than one year from previous date of last review. The Office of

Primary Responsibility for this plan is the 99th Civil Engineer Squadron Installation Management

Flight, extension 702 652-4127.

JOSHUA D. DEMOTTS

Colonel USAF

Commander

Attachment:

Nellis and NTTR Plan 12, Hazardous Waste Management Plan

Enable Mission Success through world-class installation support

ABOUT THIS PLAN

This installation-specific Environmental Management Plan (EMP) uses the U.S. Air Force’s (AF) standardized

Hazardous Waste Management Plan (HWMP) template. This plan is not an inventory of all hazardous waste (HW) requirements and practices. Where applicable, external resources and associated document links, including Air

Force Instructions (AFIs); Air Force Manuals (AFMANs); AF Playbooks; and federal, state, local, and permit requirements, are referenced to ensure current content.

Each section of this plan begins with standard language that addresses AF and Department of Defense (DoD) policy and federal requirements. The standard language is restricted from editing to ensure consistent application across the AF enterprise. Standard language is maintained by the Air Force Civil Engineer Center (AFCEC) designated

Subject Matter Expert (SME) for this plan.

Immediately following the standard text are installation-specific sections that address state, local, and installation-specific requirements and processes. Installation sections are maintained and updated by the installation HW

Program Manager or the AFCEC Section appointed to support this installation.

This document is optimized to be accessed and viewed electronically on the installation and AF eDASH website, the primary communication tool for AF EMPs.

TABLE OF CONTENTS

DOCUMENT CONTROL

Standardized HWMP Template

Installation HWMP

1.0 OVERVIEW AND SCOPE

2.0 INSTALLATION PROFILE

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

4.0 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/HW Recycling

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 – Waste Analysis Plan

Appendix B– Hazardous Waste Streams/Profiles

Appendix C– Hazardous Waste Training Plan

Appendix D– Inspection Forms

DOCUMENT CONTROL

Standardized HWMP Template

In accordance with (IAW) the AFCEC Environmental (CZ) Business Rule (BR) 08, EMP Review, Update, and

Maintenance, the standard content in this HWMP template is reviewed periodically, updated as appropriate, and approved by the HW SME.

This version of the template is current as of 06/05/2020 and supersedes the 2018 version.

NOTE: When installations update their HWMPs, they should refer to the AF EMP Repository on eDASH to ensure the most current version is applied. Installations are not required to change HWMPs after template updates.

Installation HWMP

The initial HWMP must be approved and signed by the Installation Commander (at the time of publication) as the legal HW Generator for the Environmental Protection Agency (EPA) ID assigned to this installation. The approval can be via signature or as documented in appropriate Environment, Safety, and Occupational Health Council

(ESOHC) minutes (AFMAN 32-7002 3.2.2.). NOTE: This is not a Wing Contingency Plan and is not governed by installation or Wing plans or readiness format or coordination requirements of AFI 10-401, Air Force Operations

Planning and Execution. It is governed by AFMAN 32-7002, Environmental Compliance and Pollution Prevention, Section 5.2. Hazardous Waste Management Plan (HWMP). Because this is not a contingency plan, coordination should be with EMS CFT and applicable units with roles and responsibilities in the HWMP. The plan does not require a new signature after each change in wing command.

Record of Updates – The HWMP is updated as changes to waste generation and management practices occur, including those driven by changes in applicable regulations and approved by the installation HW Program Manager as the plan Office of Primary Responsibility (OPR). Formatting and administrative changes such as the incorporation of updated regulatory language, or other minor updates are documented below.

Record of Updates

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

Record of Annual Review – IAW AFMAN 32-7002, this plan is reviewed annually by the EMS CFT. Formatting and administrative changes should be noted in the previous paragraph for record of updates as approved by the EMS

CFT Chair and do not require Installation Commander or Environmental, Safety, and Occupational Health Council

(ESOHC) approval. Substantive revisions require coordination and approval by the Installation Commander as determined by the EMS CFT Chair and/or IAW host installation procedures. Substantive changes include manpower or resource requirements changes that impact installation hazardous waste generating organizations.

Record of EMS CFT Annual Review

Review Date EMS CFT Chair Notes/Remarks

1.0 OVERVIEW AND SCOPE

This HWMP contains procedures for management of HW. In lieu of federal, or state requirements, AFMAN 32-

7002, acts as the main driver for the HWMP. The HW Playbook serves as supplemental guidance to this plan.

Where applicable, DoD, AF, and Federal Resource Conservation and Recovery Act (RCRA) requirements are included. Each installation must include supplements as warranted to address applicable State and/or local HW requirements/procedures.

Installation Supplement – Overview and Scope

• Plan 12 provides guidance and assigns responsibility for the proper management of Hazardous Waste

(HW) generated in support of the Nellis AFB and Nevada Test and Training Range (NTTR) missions, and addresses the handling, accumulation, transport, turn-in, and storage of hazardous waste and provides guidance for developing base wide and unit-specific minimization strategies. Plan 12 also outlines the procedures necessary to comply with the hazardous waste management provisions of the Resource

Conservation and Recovery Act (RCRA) and applicable state statutes contained in Nevada Administrative

Codes and Nevada Revised Statues.

• CONDITIONS FOR IMPLEMENTATION.

o Plan 12 incorporates guidance developed by the Air Force Civil Engineer Center (AFCEC) and the Defense Logistics Agency (DLA) and fulfills the hazardous waste management and minimization requirements established by AFMAN 32-7002.

o Plan 12 is applicable to all military and civilian personnel, tenant units and contractors engaged in activities that generate hazardous waste and will be executed in accordance with Annex C, Operations.

• KEY ASSUMPTIONS. Required personnel will be available.

• OPERATIONAL CONSTRAINTS. U.S. Environmental Protection Agency (U.S. EPA), state, and local regulations on the handling/disposal of hazardous waste.

• COMMAND RELATIONSHIPS. 99 CES/CEI is the Office of Primary Responsibility (OPR) for the plan and will request through the 99 ABW/CC to accomplish tasking in this plan.

• LOGISTICS APPRAISAL. Plan 12 is logistically feasible.

• PERSONNEL APPRAISAL. Plan 12 is supportable with current resources.

2.0 INSTALLATION PROFILE

Installation Profile

Scope of Plan HQ USAFWC, 99 ABW, NTTR, 57 WG, 53 WG, NELLIS AFB

TENTANT UNITS and NELLIS AFB CONTRACTORS

OPR (Civil Engineer or other designated office) 99th Civil Engineering Squadron/Installation Management has overall responsibility for implementing the HW management program and is the lead organization for monitoring compliance with applicable federal, state, and local regulations.

HW Program Manager Rene Robles

Alternate HW Program Manager Richard Bergstrand

Emergency contacts Base Fire Protection Flight at Ext 911 from a base landline or

702-652-9630 from a cell phone, Command Post at ext. 702-652-

2446, who will notify the Installation Management Office at 702-

652-4129

Waste registration numbers NV7570024110

HW generator status Large Quantity Generator

Universal waste handler status Small Quantity Universal Waste Handler

Permitted HW operations NA

Federal regulatory references Title 40 Code of Federal Regulations (CFR) Parts 262.17

State and local regulatory agencies Nevada Division of Environmental Protection (NDEP), Bureau of Sustainable Material Management (BSMM)

State and local regulatory references Nevada Revised Statute (NRS) 459.400

DLA-DS area office and/or approved

HW disposal contractors

DLA Barstow, CA

HW accumulation sites Nellis AFB CAP/90-Day Site, B-853

HW accumulation time limits 90 Days

HW generator reporting frequency Biennial

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

The AF adheres to the EMS framework and its Plan, Do, Check, Act cycle for ensuring mission success. Executive

Order (EO) 13834, Efficient Federal Operations, U.S. Department of Defense Instruction (DoDI) 4715.17, Environmental Management Systems, AFI 32-7001, Environmental Management, and International Organization for Standardization (ISO) 14001, Environmental management systems - Requirements with guidance for use, 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 manage associated risks, and instill a culture of continuous improvement. The

HWMP serves as an administrative operational control that defines compliance-related activities and processes.

Environmental Action Plans (EAPs) are developed and maintained as part of the overall EMS on eDASH. EAPs are tools that translate environmental requirements and targets into actionable plans for the HWPM and responsible personnel. HW requirements should be incorporated in installation EAPs to record monitoring and conformance for inspections and audits.

4.0 ROLES AND RESPONSIBILITIES

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

• Wing/Installation Commander

• ESOHC

• EMS CFT

• HW Program Manager/Alternate(s)

• Shop/HW Generator Personnel

• Hazardous Waste Accumulation Site (HWAS) Supervisors/Managers

• Unit Commanders

• Unit Environmental Coordinators (UECs), see AFI 32-7001 for role description.

• Contracting Officer

• Defense Logistics Agency (DLA) Disposition Services

• Tenant Organizations

• AFCEC

Detailed information about typical responsibilities for these and other roles is available in AFMAN 32-7002, applicable installation supplements, and the HW Playbook. This plan implements these responsibilities for this installation. Additional HW management-related roles and responsibilities are described throughout this plan and in referenced documents.

Installation Supplement – General Roles and Responsibilities

The Commander, 99th Air Base Wing, 99 ABW/CC, will:

o Through the 57th WG Public Affairs

• Provide timely, accurate, and positive information to the public, upon request, about hazardous waste management.

• Be notified by the Nellis Command Post (NCP) in case of an incident.

• Send a Public Affairs representative to the scene of a hazardous waste incident if news media are present or if the on-scene commander authorizes news media coverage.

• Respond to news media queries.

o Through the Commander, 99th Medical Group, 99 MDG/CC, through the 99 OMRS

Bioenvironmental Engineering Flight, SGXB, will:

▪ Review industrial operations to ensure hazardous materials identification and management is in accordance with health and environmental criteria.

▪ Conduct base surveys for all industrial facilities to reveal new areas of hazardous material activities and coordinate these findings with 99 CES/CEI.

▪ Conduct and/or arrange monitoring when required to assess impact to human health and interpret monitoring results to determine health risks.

▪ Monitor hazardous materials issued from Base Supply to hazardous material users using data compiled by the Enterprise Environmental Safety Occupational Health Management

Integrated System (EESOH-MIS) maintained by HAZMART.

▪ Review and certify the use of personal protective equipment at Initial Accumulation

Points (IAPs) and Universal Waste Collection Centers (UWCCs) operated by Air

Force personnel (Contractor operated IAPs and UWCCs require equivalent certification by the contractor’s occupational safety and health staff).

o Through the Commander, 99th Mission Support Group, 99 MSG/CC, will:

▪ Through the Commander, 99th Logistics Readiness Squadron, 99 LRS/CC:

• Ensure Safety Data Sheets (SDSs) are available to customers.

• Provide technical support to HAZMART who maintains the EESOH-MIS database.

• Report all hazardous materials issued through materiel control to the

HAZMART using the EESOH-MIS database program.

▪ Through the Commander, 99th Civil Engineer Squadron, 99 CES/CC, through 99

CES/CEI:

• Act as the 99 ABW’s OPR for the hazardous waste management program and monitor the procedures and techniques for compliance with current regulations and laws. Appoints the Hazardous Waste Program Manager who oversees the program for Nellis AFB and the NTTR.

• Act as the 99 ABW’s OPR for providing technical support and assistance in the areas of pollution prevention, waste minimization, recycling, waste characterization, waste storage, transportation, and disposal.

• Make yearly reviews of the Hazardous Waste Management Plan, Plan 12, to provide more efficient and effective operations. Identify regulatory non-compliance incidents and notify units of required corrective actions. Provide technical assistance, as needed, to unit organizations to ensure timely closure of required corrective actions.

• Act as the point of contact between the base and DLA in the areas of recycling and hazardous waste disposal operations; verify that funds for hazardous waste disposal are available.

• Maintain hazardous waste records as Office of Record including:

o Copies of all applications, permits, and permit modifications.

o Copies of annual and biennial reports.

o Copies of waste analysis and testing results.

o A copy of the Hazardous Waste Management Plan, Plan 12.

o A master log of hazardous waste training.

o Copies of accident/incident reports involving hazardous waste.

o Copies of transport manifests.

o Copies of enforcement documentation.

• Give orientation to and escort State, Federal, Air Force, and local inspectors.

• Be responsible for Hazardous Waste Training.

• Conduct quarterly inspections of all hazardous waste generating facilities to ensure regulatory compliance.

• Inspect hazardous waste containers prior to turn-in and certify on turn-in documents that approved containers are used, properly marked and labeled, and ready for transport.

• Oversee operations of the Central Accumulation Points.

o The Commander, NTTR, through the Range Support Services (RSS) Contractor with NTTR/XP

N oversight will:

▪ Ensure hazardous waste is managed correctly for range operations, remote communications sites, the O&M compound, Tolicha Peak, Point Bravo, as well as the range clearance operations conducted from salvage yards. Operate and maintain IAP’s and CAP’s IAW PLAN 12

▪ Conduct hazardous waste sampling.

▪ Collect, package, label hazardous waste. Coordinate pickup and disposal of hazardous waste through the servicing CAP and 99 CES/CEIEC. The CAP could be at NTTR.

▪ Coordinate hazardous waste collection and disposal requirements with all temporarily assigned units and tenants requesting support on the NTTR.

o DLA will:

▪ Receive, in place, properly containerized hazardous waste and assume accountability.

▪ Dispose of hazardous waste per directives and regulations

5.0 TRAINING

5.1. Hazardous waste training is required by law. All training requirements and sources are provided in the

Environmental Training Matrix on eDASH. Specific local training procedures are provided in section 5.5.

5.2. Hazardous waste training is provided only by qualified authorized personnel. Training records are maintained

IAW the Recordkeeping and Reporting section of this plan.

5.3. Hazardous waste program managers and alternates appointed in writing by the Wing Commander to sign manifests, require specific training to include HW Management Compliance Training and Department of

Transportation training to sign HW manifests. Installation HW Program Managers should complete the following in-residence courses (or equivalent): Air Force Institute of Technology (AFIT) 521, Hazardous Waste Management;

and DLA - DCPSO00510, Transportation of Hazardous Material/Hazardous Waste (Interservice Environmental

Education Review Board [ISEERB] approved). After initial course completion, refresher training is required annually for RCRA, and every 3-years for the DOT course. See training matrix for more information.

5.4. Function-Specific Training (Local In-House/On-Line Training Sources): (Group A) Organizational (non-central) Hazardous Waste Storage Area Managers, Satellite Accumulation Area (Initial Accumulation Point)

Managers, and their immediate supervisor; and (Group B) all shop personnel, and their immediate supervisors, who generate HW.

Installation Supplement – Training

• All IAP and UWCC managers are required to receive initial and annual refresher hazardous waste management training.

• 99 CES Environmental will support awareness training for the base and range communities. The level of training an individual receives will depend on the type and level of hazardous waste management duties assigned.

o IAW AFMAN 32-7002. All personnel who work with hazardous waste and their supervisors must receive and successfully complete hazardous waste training before working with hazardous waste. They must also successfully complete annual refresher training. This level of training provides for the technical and managerial requirements associated with the management of IAPs.

Topics covered in the course should include at a minimum:

▪ RCRA and State of Nevada Hazardous Waste Regulations.

▪ IAP Authorization and Closure Procedures.

▪ Waste Stream Identification and Compatibility.

▪ Facility Management.

▪ Container Management.

▪ Records Management.

▪ Waste Turn-In Procedures.

▪ Manifesting and Transportation of Hazardous Waste.

▪ Spill Prevention, Contingency Plans, and Emergency Response.

▪ Personal Protective Equipment (PPE).

▪ Hazardous Waste Minimization.

o Initial Hazardous Waste Training. Initial HW training is required for personnel who handle HW and IAP or UW managers and their alternates. This training will be accomplished in person or via video conference. It is the responsibility of individual to ensure that training is updated annually and that training certificates are maintained in the Continuity Binder. This training satisfies the requirements of 40 CFR Part 265.16 o Annual Refresher Hazardous Waste Training. All managers (HW and UW) as identified in the

IAP and/or UWCC Appointment Letter are required to receive annual HW refresher training accomplished in person or via video conference. It is the responsibility of the individual to ensure that training is updated annually and that training certificates are maintained in the Continuity

Binder. This training satisfies the requirements of 40 CFR Part 265.16

6.0 RECORDKEEPING AND REPORTING

Recordkeeping

The installation complies with the following U.S. Federal HW recordkeeping requirements as applicable based on generator status. NOTE: Retention time is defined by regulation as onsite and readily accessible for inspections and/or reference; after retention, the record(s) follow applicable Air Force Records Management rules.

Summary of HW Recordkeeping Requirements

Record* Citation Retention Time** Citation

HW determination documentation

40 CFR 262.11(f) 3 years from the date that the waste was last sent to a TSDF

40 CFR 262.11(f)

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

40 CFR

262.40(b)

HW manifest (electronic or paper)

40 CFR 262.20 3 years from the day the waste was accepted by the initial transporter

40 CFR

262.40(a)

Small Qty HWAS inspection logs

40 CFR

262.16(b)(2)(iv)

Although records are not formally required, the best management practice is to record and retain for 3 years to demonstrate compliance

N/A

Large Qty HWAS inspection logs

40 CFR

262.17(a)(1)(v)

40 CFR 264.15(d)

40 CFR 265.15(d)

For interim and permitted operations, 3 years from the date the inspection was conducted. For all other LQGs, the best management practice is to retain for

3 years to demonstrate compliance

40 CFR

265.14(d)

40 CFR

265.15(d)

Preparedness and prevention arrangements with local authorities

40 CFR

262.16(b)(8)(vi)(B)

The federal regulations do not offer a minimum retention time, but the best management practice is to retain the plan while active and for

3 years thereafter to demonstrate compliance

N/A

Consolidation of HW received from very small quantity generators.

40 CFR 262.17(f) 3 years from the date the HW was received from the very small quantity generator

40 CFR 262.17(f)

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

40 CFR

262.40(b)

Land restricted waste determination

40 CFR 268.7(a)(1) 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(a)(8)

Land restriction notice and certification

40 CFR 268.7(a)(2) 3 years from the date the waste was last sent to a TSDF

40 CFR

268.7(a)(8)

Notification of intent to export waste

40 CFR 262.83(b) 3 years from the date the HW was accepted by the initial transporter

40 CFR

262.83(i)(1)(i)

Waste export confirmation of receipt and exception reports

40 CFR 262.83(h) 3 years from the date the HW was accepted by the initial transporter

40 CFR

262.83(i)(1)(iii)

Record* Citation Retention Time** Citation

Annual report (required of primary exporters of HW)

40 CFR 262.83(g) 3 years from the date the HW was accepted by the initial transporter

40 CFR

262.83(i)(1)(ii)

Employee training records

(including appointment letters for key HW personnel)

40 CFR

262.16(b)(9)(iii)

40 CFR

262.17(a)(7)(iv)

40 CFR 264.16(d)

40 CFR 265.16(d)

For interim and permitted operations-current personnel: until closure of the site; Former personnel: 3 years from date the individual last worked there. For all other LQGs and SQGs, the best management practice is to retain for

3 years to demonstrate compliance

40 CFR

262.17(a)(7)(iv)

40 CFR

264.16(e)

40 CFR

265.16(e)

*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

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 that the records required by law or external regulation, should be readily available on-site. Records required by AF Record Retention requirements can be archived.

Reporting

The HW Program Manager, and other designated personnel, generate needed reports from the Enterprise

Environmental, Safety, and Occupational Health - Management Information System (EESOH-MIS).

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

Environmental Reporting (EASIER) database.

Installation Supplement – Recordkeeping and Reporting

• Records Management

IAP

o All IAP documentations are required to be maintained in a Continuity Binder to provide for consistent and uninterrupted management of hazardous waste.

o The following provides a listing of the required records and the organizational format to be used for hazardous waste continuity binders:

▪ Table of Contents.

▪ Tab A. Copies of guidance letters and memoranda.

▪ Tab B. Copies of AF Form 2005 or DD Form 1348-1.

▪ Tab C. Weekly Container Assessment Logs.

▪ Tab D. Training Documentation. For IAPs, the only training documents required are copies of the initial and current annual hazardous waste training certificates. For Central Accumulation

Sites, the following additional information is required:

• Job title and position descriptions for hazardous waste management personnel.

• A log documenting program training requirements and frequency, and the dates of initial and refresher training to include the instructor’s name and course title.

▪ Tab E. A current copy of the following:

• Nellis Hazardous Waste Management Plan 12, and

• If applicable, Nellis AFB Plan 19-1

▪ Tab F. Inventory list of available personal protective equipment and spill kit contents.

▪ Tab G. Copies of Safety Data Sheets (SDSs) for all products used in a shop, or a single page identifying the location where SDSs are filed;

Hazardous Waste Profile Sheets from previous waste turn-ins (if available) and analytical data (if applicable).

▪ Tab H. Copy of Initial Accumulation Point Authorization Form.

▪ Tab I. Copy of UWCC Authorization Form

▪ Tab J. Copy of Primary and Alternate AP Manager appointment letter.

o Records corresponding to the current fiscal year must be maintained in the

Continuity Binder. Historical records must be kept on file for a minimum of three years.

• A copy of the Hazardous Waste Accumulation Authorization Form and the Primary/ Alternate appointment letter must be kept in the Continuity Binder.

• Documentation supporting the required hazardous waste training for applicable personnel must be current and available for assessment. Refer to Appendix 7, Personnel Training for requirements.

• Copies of completed AF Form 2005 for all waste, reclaimable, and recyclable material transferred to 90-

Day/180-Day accumulation points or the Recycle Center must be maintained in the binder. Records must be kept for three years, and the current year must be in the binder. An AF Form 2005 and instructions for filling out the form can be found at Tab B. (NOTE: Maintain the turn-in logs or receipts for other items such as wipers and rags that are laundered, used oil pick-ups/turn-ins, etc. These records should document the amount picked-up/turned-in, what was picked up/turned-in and the date of turn-in. These records are very useful for tracking and evaluating a unit’s waste generation activities for pollution prevention and waste minimization goals.

• Assessment logs documenting the frequency and results of container assessments must be current and available for assessment purposes.

• Current SDSs, matching the products used by manufacturer and product precisely, and a copy of this plan

(Nellis, Hazardous Waste Management Plan 12) will be maintained at each shop that manages an IAP.

Plan 12 may also be kept electronically. SDSs can be obtained from the HAZMART, 702-652-4352/9856, the material manufacturer, or through Bioenvironmental Engineering.

UWCC

o A continuity binder is not required for the UWCC, but the following must be kept:

▪ The UWCC authorization form and any appointment letters.

▪ Copies of training records for the UWCC managers.

▪ Copies of completed AF Form 2005 for all UW transferred to CAP.

▪ Records must be kept for three years, and the current year must be in the binder.

7.0 PROCEDURES

This section contains procedures for managing HW from identification, accumulation, offsite transportation, and disposal. The HW Program Manager ensures that appropriate procedures are properly communicated and followed by all necessary personnel.

7.1 Waste Inventory

A current waste inventory can be generated within EESOH-MIS using the Ad-Hoc Reporting Tool or by completing the following steps:

• Log into EESOH-MIS, select the “Reporting” option, and select “Hazardous Waste” to generate the Waste

Site Waste Stream Summary Report.

The resulting waste inventory report can be placed into Appendix B, Hazardous Waste Streams/Profiles.

Installation Supplement – Waste Inventory

Waste Inventory at NTTR is tracked via the Hazardous Waste 2023.accdb database.

7.2 Waste Identification

The HW Program Manager determines the nature of waste based on a detailed qualitative analysis of the regulated waste generating process, associated SDS information, and coordination with generating activity personnel involved in the use of hazardous materials. If uncertainties about a waste stream exist, the HW Program Manager pursues waste stream sampling and analysis IAW the Waste Analysis Plan (WAP) found in Appendix A.

The WAP details how waste is evaluated and analyzed, a description of the testing and analytical methods used, the

HW sampling methods used, the location of samples taken for analysis and frequency, sample documentation, sample quality assurance and quality control procedures, and sample request procedures.

Generator knowledge and the results of the WAP are used to minimize waste re-characterizations to those instances where a process change has occurred, or the waste stream is highly variable.

Installation Supplement – Waste Identification

The WAP describes how waste determinations are made. The Plan includes how waste are evaluated and analyzed, sampling methods, and description of analytical methods, sample quality assurance and quality control procedures. This appendix represents an overview of the detailed waste analysis procedures established at Nellis

AFB and NTTR. For the latest plan, please refer to Sampling and Analysis Plan, June 2021

7.3 Container Management

Container management procedures are as follows:

• Containers storing HW must be in good condition and meet transportation and other applicable requirements. “Good condition” means there should be no severe rust, no sharp-edged creases or dents, no bulging heads, or no severe structural defects. If these conditions exist, then the waste should be place in a container in good condition if feasible otherwise the container should be placed in an overpack container.

Contact the Hazardous Waste Program Manager for guidance.

• Ensure that the waste material will not react with the container itself.

• Use plastic or plastic-lined steel drums to safely store corrosive waste.

• Immediately transfer the contents of a leaking container to another container or over pack into a salvage drum.

• Containers with free liquid or drum contents on top must be cleaned or over packed in the case of a leak.

• Containers must remain closed at all times except when adding or removing waste.

• Adequate headspace must be always maintained when filling a container to account for content expansion.

The required headspace is unique to each waste stream and expected storage conditions. For liquids and volatile chemicals, a general rule is to not fill to more than 85% of container capacity to allow for temperature changes, and this equates to approximately four inches of headspace in a typical 55-gallon drum. The ultimate requirement is performance based, such that drums do not bulge or leak. A good inspection process will enable any recommendations for specific waste streams as appropriate.

• Containers holding HW must not be opened, handled, or stored in a manner which may rupture the container or cause it to leak.

• Containers of flammable liquids must be grounded when transferring flammable liquids from one container to the other.

Installation Supplement – Container Management

• Container Management o Units or shops will store HW in appropriate containers while HW is being collected at the IAP.

The respective CAP will provide the proper containers that are compatible with the waste.

Consult the Hazardous Waste Program Manager, Hazardous Waste Inspector or the CAP personnel before re-using any container.

o Containers must be configured so as to prevent inadvertent mixing and contamination from potentially incompatible materials or waste. Use containers only for what they are specifically designated to hold and use the smallest size container necessary to effectively manage the quantity and frequency of waste generated. For example, use a 20 or 30-gallon container instead of a 55-gallon container if the waste is accumulated very slowly over time. Thoroughly inspect containers for physical damage, rust, and corrosion. If used containers are obtained, check for traces of prior materials that may be incompatible with the waste before placing hazardous waste into them.

o Containers must be made of, or lined with, materials that will not react with and are otherwise compatible with the hazardous waste to be stored.

o All containers holding liquids in the IAP will be stored on spill pallets that provide secondary containment for spills/leaks. Containers holding ignitable or reactive waste must be properly bonded and grounded prior to any transfer of liquids.

o Containers holding waste must be kept tightly closed at all times except when it is necessary to add or remove waste. If a funnel is used, it shall have a closable lid attached to it. Lids and bungs must be tightened to prevent vapors from escaping the container and to prevent spillage in the event the container is overturned.

o Do not fill liquid containers to more than 4/5ths of the container’s capacity. Allow 6-inches of headspace in containers to allow for the expansion of liquids.

o Containers must be inspected at least weekly for leaks or signs of damage. If leaks develop, take appropriate remedial action. Document weekly assessments of the containers on the Weekly

Container Assessment Log.

WEEKLY CONTAINER ASSESSMENT LOG

In accordance with Nevada Administrative Code (NAC 444.8677), container assessments must be completed and documented weekly. Complete the following questions for each container at your Initial Accumulation Point and document any discrepancies noted. Assessment records must be maintained for three years. This log must be maintained in TAB C of the Continuity Binder for each IAP.

a. Are the containers labeled properly?

- “HAZARDOUS WASTE”

- Generic description of waste, i.e., “Jet-A Pads” or “Solvent Rags”.

b. Are container lids kept closed and tightened until waste is to be added or removed?

c. Are waste properly segregated?

d. Are any containers leaking, damaged or overfilled?

e. Is there any evidence of heat generation (bulging lid or sides of drums)?

DATE / TIME/ INITIALS DATE / TIME / INITIALS DATE / TIME / INITIALS

7.4. Labeling and Marking

Containers used for the accumulation and transportation of HW are properly labeled IAW applicable laws and regulations.

Each container is properly marked and labeled from an IAP to HWAS to disposal/turn-in. The waste-generating activity ensures that the label on each waste container is clearly visible for inspection. During accumulation at an

IAP, HW containers are marked with the following:

• The words “Hazardous Waste”

• A description of the contents of the container

• The hazards associated with the waste

Once an IAP accumulates more than 55 gallons of HW (or 1 quart of acute HW), the IAP site manager marks the container with the date on which 55 gallons (or 1 quart of acute HW) is exceeded and removes the excess of 55 gallons (or 1 quart of acute HW) within three days.

HW containers 110 gallons or less that are shipped offsite are marked with the following:

• “Hazardous Waste – Federal Law prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency”

• Generator’s name and address

• Generator’s EPA ID Number

• Manifest tracking

These markings are:

• Durable

• In English

• Printed on or affixed to the surface of a package or on a label, tag, or sign displayed on a background of sharply contrasting color

• Unobscured by labels or other attachments

• Located away from any other markings that might substantially reduce visibility or effectiveness

Universal waste (UW), or a container in which a UW is contained, is labeled and marked clearly with the date the material became a waste and the name of the waste, as described below:

• UW batteries must be labeled with any one of the following phrases: “Universal Waste—Battery(ies),” or

“Waste Battery(ies),” or “Used Battery(ies)”

• UW thermostats must be labeled with any of the following phrases: “Universal Waste-Mercury

Thermostat(s),” “Waste Mercury Thermostat(s),” or “Used Mercury Thermostat(s)”

• UW pesticides must be labeled with one of the following phrases: “Universal Waste—Pesticide(s)” or

“Waste-Pesticide(s)”

• UW lamps must be labeled with one of the following phrases: “Universal Waste—Lamp(s),” or “Waste

Lamp(s),” or “Used Lamp(s)”

Installation Supplement – Labeling and Marking

• Container Labeling.

o IAP Containers o All containers holding hazardous waste at IAPs must have a hazardous waste label affixed immediately upon placing waste in the container.

• Empty containers must not have a Hazardous Waste label affixed to them. Labels may be obtained from the CAP. For IAPs, the Accumulation Start Date (ASD) is not recorded until the 55-gallon limit is reached, transfer to the CAP and dated only by CAP personnel. DLA contractor will put completed HW labels with EPA waste codes, proper DOT shipping name, etc. on the waste prior to off-site shipment.

Hazardous waste labels for containers located at IAPs must contain the following information:

o The words: “HAZARDOUS WASTE”;

o A brief, generic description of the waste (i.e., “Sandblast Debris”).

UWCC Containers o UW (batteries, mercury thermostats, pesticides and fluorescent lamps) accumulated at the UWCC must be labeled with the words “UNIVERSAL

WASTE” followed by a descriptor identifying the particular type of waste and the date that the first item was placed in the collection container.

Examples of proper labels include: “UNIVERSAL WASTE – BATTERIES

(NiCad), 30 Apr 07” or “UNIVERSAL WASTE – FLUORESCENT LAMPS, 30 Apr 07”

7.5 Accumulation Area Management

Accumulation area management procedures are as follows:

• IAPs are used to accumulate up to 55 gallons of HW or 1 quart of acute HW.

• If HW or acute HW are accumulated in excess of these amounts, the generator marks the container with the date the amount was exceeded and transfers the container to a HWAS or TSDF within 3 days.

• HW is accumulated in a HWAS for up to 90 days for a large quantity generator (LQG), or 180 days (270 days if waste has to be shipped over 200 miles) for a small quantity generator (SQG)

• HWASs comply with all applicable federal, state, and local accumulation requirements, including proper waste segregation.

Installation Supplement – Accumulation Area Management

IAP Authorization and IAP Managers/Alternates Appointments.

o An IAP must be physically located at or near the point of waste generation where waste will be stored until transferred to the 90-Day or 180-Day site also referred to as the CAP. All IAPs must be authorized prior to storing waste. Shops will complete an Initial Accumulation Point

Authorization Form, signed by the Squadron Commander or their designee, and coordinate the authorization requests for signature and approval by the appropriate safety office, fire protection organization, and Environmental Compliance (99 CES/CEIEC). Final approval is given by 99

CES/CEIEC, Hazardous Waste Program Manager or their designee. The only time the IAP

Authorization Form needs to be re-submitted if waste are added or deleted from the original, the

IAP location has changed, or the original IAP Authorization Form has been lost.

o Completed IAP Authorization Forms are stored in Tab H of the Continuity Binder.

o Appointments, additions or deletions of IAP Managers and/or alternates shall be done through an Appointment Letter.

o The IAP and/or UWCC Appointment Letters shall be signed by the Squadron

Commander or their designee and submitted to 99 CES/CEIEC.

o Completed Appointment Letters are stored in Tab J of the Continuity Binder.

o The IAPs must be under the control of the IAP Manager. It must be locked or otherwise secured to prevent unauthorized access and must be situated in an area away from vehicular traffic.

o Each IAP must have a sign posted that reads:

▪ Initial Accumulation Point

▪ Hazardous Waste

▪ No Smoking o Weekly assessments of the area and containers must be performed using the Weekly

Container Assessment Log above (NOTE: In addition to the Weekly Container

Assessment Log, which is mandatory, a copy of the IAP Checklist is also provided below. As a best management practice, IAP managers are strongly encouraged to use this checklist as a guide for maintaining compliance with Air Force and State/Federal regulations) The IAP Checklist is based on USEPA requirement for IAPs.

o A spill kit must be maintained near the IAP and/or UWCC in the event of a hazardous waste/substance spill. The spill kit must be appropriate for materials managed and kept closed. Reportable spill quantities (RQ) for hazardous waste vary and can be as low as one pound or approximately one pint. The Facility Response Plan, NAFB 19-1 lists specific reportable quantities. Hazardous substances of any quantity, or oil spills of 5 gallons or more require immediate reporting to the Environmental Spill Coordinator at

702-652-6115. After hours spills must be immediately reported to the Command Post

702-652-2446.

o The IAP and/or UWCC Managers will ensure that all waste containers are appropriately marked, in good condition, and kept closed except when adding waste.

o Notify the respective CAP if there are any changes in waste generation (such as significant volume changes, change in materials used, or changes in handling practices).

o Requests for closure of an IAP may be done through a Request for Closure of IAP Memo signed and submitted to 99 CES/CEIEC. The Request for Closure IAP Memo shall be signed by the Squadron Commander or their designated responsible official.

NELLIS AFB

INITIAL ACCUMULATION POINT CHECKLIST

Building: IAP #: Base: Unit: Shop:

Waste Stream(s):

Managers: Primary/Phone/Training

Alternate/Phone/Training

Letter Dates: Authorization Appointment

Assessor: Date/Time:

I. RECORDS MANAGEMENT SAT UNSAT N/A

Current Guidance Letters and Memos

AF Form 2005s (Completeness/Maintained for 3 Years)

Weekly Container Assessment Logs (Date, Time & Initials/Maintained for 3 Years)

Training Documents (Primary and Alternate(s))

Copies of All Applicable Air Force Plans (Nellis AFB Plans 12, 19-1, 19-14)

Inventory list of available Personal Protective Equipment & Spill Kit contents

MSDS or Locator Page, Analytical Data (For Each Waste Stream)

Current Initial Accumulation Point Authorization Form

Current Appointment Letter for Primary and Alternate IAP Managers

II. FACILITY MANAGEMENT

IAP located at or near point of generation

Posted Signs ( "Initial Accumulation Point", "Hazardous Waste", "No Smoking" )

Housekeeping (Evidence of Spills and Leaks)

Proper Segregation of Waste (Proper Storage of Incompatible Waste)

Spill Prevention Kit

Personal Protective Equipment

Management of authorized waste from designated points of generation

Work Areas and Other Storage Areas (Free of Hazardous Waste Problems)

Waste Baskets & Dumpsters (Disposal of Improper Items)

Additional requirements per Authorization Letter.

III. CONTAINER MANAGEMENT

Container Integrity (Evidence of Leaks, Damage, Heat Generation, Bulging, etc.)

Waste compatible with container

Approved/Authorized Containers (UN POP or Equivalent)

Container Closed/Secured, except when adding or removing waste

Hazardous Waste Label (Properly Filled Out)

55-gallon Limit (Total Volume of Accumulated Waste)

No Date on container (unless 55-gal limit exceeded)

Secondary containment

Containers properly grounded

Outdoor IAP Security (Sufficient to Prevent Unauthorized Access?)

Outdoor IAP Protection from Forces of Nature (Sunlight, Rain, Wind, etc.)

Corrective Action(s) / Remarks

Assessor’s Signature Date AP Manager’s Signature

• UWCC Authorization Appointments o Units may request that a UWCC be established to service their organization by submitting a UWCC Authorization Form (Tab A) to 99 CES Environmental. This form is signed by the Squadron Commander, Squadron Commander appointed

UEC, Shop Supervisor, or other responsible official and coordinated through the

99 CES/CEIEC. Addition or deletions of the Managers may be done through an appointment letter submitted to 99 CES/CEIEC. The only time the Authorization

Form needs to be re-submitted is if waste is added or deleted from the original or the UWCC location has changed.

o The authorization request form must include information identifying the preferred location for the UWCC and a list of waste to be managed. In addition, the requesting organization must identify an individual or individuals responsible for maintaining the UWCC. Store in Tab H of the Continuity Binder.

o The only waste allowed to be accumulated at UWCCs are batteries (nickel cadmium, lithium ion, and lithium metal hydride), mercury containing equipment, pesticides, and fluorescent lamps.

o UWCCs must be clearly identified with appropriate signage "UNIVERSAL

WASTE COLLECTION CENTER."

o The UWCC must be under the control of the Manager. It must be locked or otherwise secured to prevent unauthorized access.

o The UWCC Manager will ensure that all waste containers are appropriately marked, in good condition, and kept closed except when adding waste.

o A spill kit and fire extinguisher able to handle the types of UW being handled in the event of a spill will be maintained at the site.

7.6 Transportation

The HW Program Manager has overall responsibility for the transportation of HW from an IAP to an HWAS, and from an HWAS to the disposal facility. The HW Program Manager ensures:

• All transportation over public highways are conducted IAW applicable Department of Transportation

(DOT) requirements.

• Containers are DOT approved.

• Transporters have the appropriate training.

• Uniform HW manifests are prepared for offsite transportation (electronically or paper)

• All necessary documentation has been completed and records are maintained IAW all applicable federal, state, and local requirements and the AF Records Disposition Schedule.

Installation Supplement – Transportation

This appendix provides instructions for the transportation of hazardous waste. Comply with the requirements of

49 CFR Subchapter C, Hazardous Materials Regulations.

• DLA is responsible for managing the waste disposal contract and arranging transportation of hazardous waste to the TSDF.

o The Nellis CAP prepares all necessary turn-in documentation and forwards to DLA for processing.

o DLA reviews documentation and coordinates waste pick-up with waste disposal contractor and the respective CAP.

o Waste disposal contractor ensures waste is packaged properly before transportation.

Nellis and NTTR Personnel may transport hazardous waste from their shop to the CAP at installation or range which their shop resides, so long as the intended route is only on roadways which are within the installation or range or are along the perimeter of the installation or range

7.7 Turn In/Disposal

The turn in procedures contained in DoD 4160.12-M. DLA Disposition Services are followed. In the event an alternate route for disposal is needed, a waiver will be obtained with proper justification and approval.

Containers are inspected prior to turn-in to ensure that container management procedures have been followed and that containers are properly labeled and in good condition. If the container is not in good condition, contents are transferred to a container that is in good condition.

Installation Supplement – Turn In/Disposal

• Turn-in procedures.

o The process flow diagram below illustrates the hazardous waste disposal process for waste turned in to the CAP.

The shop generates hazardous waste for turn-in to

CAP

IAP Manager submi ts AF 2.005, and SDSs or analytical data to CAP for review and concurrence

CAP schedules waste pick-up date/time

IAP submits approved documentation and waste to

CAP

CAP generates DD Form 1348-1 and submits to DLA to schedule waste pick-up at CAP

DLA prepares Removal Order (RO) for transport, treatment, and disposal of hazardous waste

Waste contractor reviews RO and arranges for site visit to inspect waste at CAP prior to shipment

Waste Contractor inspects containers, verifies waste contents, prepares containers and manifest for transport, and arranges for licensed transporter to pick-up waste

99 CES/CEIEC Hazardous Waste Program Manager or designee reviews RO and all paperwork before signing Uniform Hazardous Waste Manifest

Waste is transported to final disposal site

Signed manifest returned to 99 CES/CEIEC o The following flow chart illustrates the hazardous waste disposal process for NTTR. In general, the processes are very similar.

IAPs submit AF Form 2005, SDSs/Analytical data to

NTTR

RSS II Contractor submits AF Form 2005, Hazardous

Waste Profile Sheet, and SDSs or analytical data to

Nellis CAP for review and concurrence

RSS II Contractor issues DD Form 1348-1A and submits to DLA for review and concurrence.

Upon approval of paperwork DLA arranges for waste pick-up in place

For pick-up in place, the waste contractor inspects containers, verifies waste contents, prepares containers and manifests for transport, and arranges for licensed transporter to pick-up waste

99 CES/CEIEC Hazardous Waste Program Manager or designee reviews RO and all paperwork before signing Uniform Hazardous Waste Manifest

Waste is transported to final disposal site

Signed manifest returned to NTTR CAP o When hazardous waste containers are ready for turn-in, all IAP managers will…