Attach__No__1B_-_Avon_Park_HWMP.pdf

U. S. AIR FORCE

HAZARDOUS WASTE MANAGEMENT PLAN

Avon Park Air Force Range

9/23/2021

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 and/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:

01 Using New Standard

Template (June 2020)

9/23/2020 598 RANS/RMFI

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 23 September 2020 William Buchans Upgraded plan to new Standardized

Template 23 September 2021 William Buchans Reviewed – No update to plan

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

The primary goal of the Hazardous Waste Management Plan (HWMP) is to provide a management plan that gives personnel responsible for hazardous waste a tool to effectively manage waste. This plan will assist Avon Park AFR personnel who generate, work with, or are exposed to a hazardous waste or a hazardous material with the safe and proper management of substances that may have an adverse affect on life, human health, or the environment

Avon Park AFR, due to its non-routine missions, can be classified in one of three ways: a CESQG (this means that APAFR produces less than 100 kilograms in one month), a SQG. (This means that Avon Park AFR either produces less than 1,000 kilograms (approximately 265 gal, or 2,200 lb) but more than 100 kilograms (25 gal, or 220 lb) of hazardous waste or produces less than 1 kg of acute hazardous waste per month), or a LQG (This means that APAFR generates more than 1,000 kilograms of hazardous waste in a month). During its routine operations (primarily vehicle maintenance), Avon Park AFR stores and uses relatively small amounts of oils, paints, solvents, thinners, adhesives, gasoline, cleaners, batteries, acids, bases, and compressed gases. However, non-routine operations, such as target maintenance, expired shelf-life chemicals and equipment, and ERP waste generation, may elevate the facility to LQG status for any 30 day period within the year.

Since Avon Park AFR is classified as a SQG (2013), it is required to manage, accumulate, store, and handle hazardous wastes in compliance with federal, state and DoD policies. It is anticipated that the Avon Park AFR activities, as discussed below, will maintain its status as a SQG until such time that operational changes at the facility occur.

2.0 INSTALLATION PROFILE

Installation Profile

Scope of Plan Avon Park Air Force Range, including the Florida Army National Guard Unit Training Equipment Site.

OPR (Civil Engineer or other designated office)

598 RANS/RMFI 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 Bill Buchans Compliance Manager

Alternate HW Program Manager Brent Bonner, Environmental Flight Chief

Emergency contacts Range Fire Department (First Response) 863-453-4117

Waste registration numbers FL8572128587 HW generator status Small Quantity Generator (SQG) Universal waste handler status SQG Permitted HW operations HSWA Permit for Corrective Action.

Federal regulatory references 40 CFR 261 through 271 State and local regulatory agencies Florida Department of Environmental Protection State and local regulatory references FAC, Chapter 62-730.030 DLA-DS area office and/or approved HW disposal contractors

DLA

HW accumulation sites Building 27 HW accumulation time limits SQG – 180 Day HW generator reporting frequency Not Applicable because of SQG status.

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

• Initial Accumulation Point (IAP) and 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

Environmental Occupational Safety and Health Council

The ESOH Council Representative or his designee will:

• Ensure that management of hazardous waste on Avon Park AFR complies with applicable portions of 40 CFR 260—271 and Florida hazardous waste management regulations.

• Ensure the HWMP is reviewed at least annually.

• Ensures all hazardous waste manifests are signed.

• Ensures that all personnel involved with hazardous waste have required initial and refresher training

• Ensures that all enforcement actions are resolved quickly.

Installation Asset Management - Environmental Flight

The Installation Asset Management - Environmental Flight will:

• Oversee and manage the hazardous waste program.

• Review/Update the HWMP.

• Maintain training documentation for a minimum of 3 years. Permanent records will be maintained by the hazardous waste program manager.

• Prepare hazardous waste reports and compliance documentation as required by EPA, the state regulatory agency, and USAF instructions.

• Perform hazardous waste compliance surveys and maintain these records.

• Prepare permit applications and annual updates as required.

• Provide all applicable records to representatives of EPA or State of Florida who are duly designated by the Administrator and coordinate with these agencies on hazardous waste management procedures.

• Maintain routine liaison with AFCEC, EPA, and the state regulatory agency in regard to hazardous waste inspections, rule interpretation, and problem resolution.

• Prepare fact sheets on the hazardous waste management program as requested by Public Affairs.

• Assist waste generating activities in hazardous waste identification, waste management, waste minimization, waste recycling, waste storage, and disposal.

• Maintain written operating records, including: facility layout plan, IAP location, waste analysis results, contingency plan implementation summaries, and records and results of inspections.

• Conduct or coordinate hazardous waste management training for personnel who handle or who may otherwise be involved in the management of hazardous waste.

• Ensure funding requirements are identified and allocate funds based on regulatory requirements.

• Ensure an authorized federal employee signs hazardous waste manifests

Avon Park AFR Hazardous Waste Program Manager

The HW Program Manager will:

• Oversee the activities of the Base Operating Support Hazardous Waste Management Personnel.

• Provide emergency notification and reporting to all installation, state, federal, and headquarters agencies.

• Review, update, the HWMP.

• Ensure that hazardous waste management training is provided annually for organization personnel.

• Inspect the hazardous waste accumulation site (HWAS) and maintain copies of the documented inspection forms.

• Ensure that designated responsibilities of the Environmental Flight are carried out.

• Assign waste stream numbers.

• Direct or assist in directing the collection of samples for hazardous waste determination and forward them to a local contract laboratory for analysis in accordance with the sampling and analytical requirements specified in EPA SW-846 and the Avon Park AFR Waste Analysis Plan

(WAP).

• Forward analytical results to appropriate Range organizations (Environmental Flight, Range Support Operations).

• Assist Range generating activities in the interpretation of analytical results.

• Receive and review hazardous materials information sheets as necessary.

• Develop and update the Avon Park AFR waste stream inventory and WAP.

• Specify PPE to be worn by personnel occupationally exposed to or who may otherwise manage hazardous waste.

• Participate in hazardous waste training programs and exercises.

• Coordinate with accumulation site managers, Fire Department, and the Environmental Flight on the location of hazardous waste accumulation sites.

Base Operating Support Hazardous Waste Management Personnel

The Base Operating Support - Hazardous Waste Management Personnel will:

• Operate and maintain the Initial Accumulation Site (IAP).

• Generate and maintain hazardous waste turn-in documentation as required.

• Conduct routine inspections of Initial accumulation sites.

• Maintain centralized files.

• Ensure that containers are labeled in accordance with DOT requirements.

Public Affairs

The 598 RANS/RMD (Additional Duty) will:

• Act as the focal point for inquiries from the news media and concerned citizens regarding hazardous waste and any hazardous waste incidents, should they occur.

• Assist the Range Support Manager during situations involving hazardous waste incidents by keeping interested news media and the public aware of events and curtailing rumors through the dissemination of coordinated, accurate information. Respond to inquiries regarding the accident/incident site, through the Command Post, and to the Public Affairs duty section where an information center may be established.

• Ensure that the presence of hazardous waste in a contained area will probably not constitute reasonable cause to forcibly deny access to the area by accredited news media representatives.

Applicable security and safety provisions will apply, however. Under no circumstances will Public Affairs Office personnel escort news media representatives into a hazardous or potentially dangerous area.

Supervisors of Areas That Generate Hazardous Waste

Supervisors of areas that generate hazardous waste will:

• Provide safe equipment and locations for IAPs and accumulation sites.

• Ensure that the management of hazardous waste accumulation sites complies with federal and state hazardous waste management regulations.

• Allow appropriate facilities, shops, and equipment to be inspected for hazardous waste management regulatory compliance by the Environmental Flight, and authorized state or federal inspectors.

• Ensure that all personnel who handle hazardous waste or who are otherwise involved in hazardous waste management receive annual training.

Hazardous Waste Accumulation Site Managers and Initial Operators

The hazardous waste accumulation site manager and initial operators will:

• Assume overall responsibility for management of the hazardous waste accumulation site or initial.

• Ensure that the accumulation site or initial has appropriate warning signs posted and that the sites maintain emergency response equipment applicable to the hazards that may be posed if a hazardous waste should be released.

• Ensure that the accumulation site has a spill kit.

• Ensure that an approved fire extinguisher is readily available if flammable hazardous waste is stored in the accumulation site.

• Perform and document inspections of the accumulation site.

• Ensure that hazardous wastes are collected and stored in approved containers.

• Ensure that hazardous wastes labeled and stored in accordance with DOT requirements are in appropriate (authorized) containers.

• Maintain hazardous waste containers in proper condition (e.g., no pitting, no sharp edge creases or dents, no material defects, no bulging heads).

• Ensure that containers are kept closed except when adding or removing waste from the containers.

• Ensure that all hazardous waste is placed in an installation-approved accumulation site or at a initial location at or near the point of generation and that the environmental coordinator is aware of the location.

• Ensure that hazardous waste containers are properly labeled.

• When a hazardous waste spill is detected, stop all other actions and contain the spill based on unit capability and resources only if it is safe and appropriate training has been received.

• Notify the Fire Department in the event that a spill exceeds the capabilities of the hazardous waste accumulation site staff.

Resource Protection Flight (Fire Department)

The Resource Protection Flight will:

• Respond to all hazardous waste spills and hazardous waste releases as directed by the Avon Park AFR Spill Prevention, Control, and Countermeasures Plan (SPCCP).

• Assist in determining practical and environmentally sound locations for IAPs or accumulation sites.

All Unit Generators

All sections that generate hazardous waste will:

• Minimize hazardous waste generation wherever possible.

• Ensure that all hazardous waste is properly handled, stored, and labeled as specified in the Avon

Park AFR HWMP, SPCCP.

• Use only DOT-approved containers for hazardous waste destined for disposal.

• Submit data as required on quantity, identity, and collection methods for hazardous waste generated.

• Designate a hazardous waste manager and an alternate hazardous waste manager. Submit the current managers’ names, and duty phone numbers to the Avon Park AFR Hazardous Waste Program Manager.

EOD

EOD will:

• Develop an annual range clearance schedule.

• Maintain a written operating record as required by 40 CFR 264.73 and 264.74.

• Maintain a log of explosives that are destroyed by explosive class, net explosive weight, and origin. Forward a copy to RMFI annually by 1 February.

• Ensure that all munitions items are accountable from receipt to destruction.

• Maintain all hazardous waste documentation for a minimum of 5 years.

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

In accordance with AFPAM 32-7043, hazardous waste training is required for all personnel working in permitted hazardous waste management facilities, IAPs, and HWASs (40 CFR 264.16) and who fit into any of the following categories:

• Permitted hazardous waste storage facility,

• Hazardous waste accumulation sites, or

• Emergency response organizations that may respond to hazardous waste incidents.

In addition to personnel identified above, all personnel who perform any of the following tasks must receive hazardous waste training:

• Decide which wastes are hazardous wastes;

• Add hazardous waste into accumulation containers or tanks at accumulation sites;

• Remove hazardous waste from accumulation tanks or containers;

• Transport hazardous waste to or from accumulation sites;

• Transport hazardous waste to or from storage and treatment units;

• Respond to spills, fires, or explosions involving hazardous waste

• Complete hazardous waste manifests, annual reports, or exception reports;

• Inspect hazardous waste accumulation sites or TSDFs;

• Operate accumulation sites;

• Work at permitted or interim status TSDFs; or

• Conduct any tasks involving occupational exposure to or which required management of hazardous waste.

Training Requirements

Although the USAF has developed a slide presentation and computer-based training program, hazardous waste training has been conducted annually at Avon Park AFR by a contractor who designs an installation-specific program to meet the needs of Avon Park AFR. The training program discusses the following subject areas:

• Introduction of RCRA,

• Identification of hazardous wastes,

• Accumulation and IAP management,

• On-installation transportation,

• Container marking and labeling,

• Personnel and fire safety,

• Waste turn-in procedures,

• Spill prevention and response to emergencies,

• Manifesting and transportation of hazardous waste, and

• Pollution prevention/waste minimization.

A combination of classroom and on-the-job training is to be used to satisfy the training requirements.

Training Frequency

All employees involved in hazardous waste management are trained in the minimum requirements. The required training must be successfully completed by all the personnel described above. For new personnel, training must be successfully completed prior to their assignment to a position involving the handling or management of hazardous waste. Until that time, untrained personnel must not perform any tasks involving hazardous waste management unless they are supervised by trained personnel. Facility identified above must take part in an annual review of the training program.

Training Records

Training records will be maintained by supervisors and the Environmental Flight. Records must be kept on file for at least 3 years after an employee has left the organization and permanently for as long as the employee works in that organization. Records may appear on computer databases of USAF-generated forms. The master training record will be maintained with the Environmental Flight and will consist of a master list of names of personnel trained in hazardous waste management. The following training-related records will be maintained by the Environmental Flight.

• The job title for each position at the installation related to hazardous waste management and the name of the employee filling each job.

• A written job description for each position related to hazardous waste management. For the purposes of RCRA training records, the job description need only describe the job as it relates to the management of hazardous waste and must include the requisite skills, education, or other qualifications, and the duties of facility personnel assigned to each position.

• A written description of the type and amount of both introductory and continuing training that will be given to each person filling a position related to management of hazardous waste.

• Records that document that the training or job experience required to meet the training requirements have been provided to and completed by installation personnel. These records must be kept for current employees as long as they work at the installation, and for an additional 3 years after the date they leave the installation (or stop working at a position related to hazardous waste management). Training records may accompany personnel transferred to another installation.

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)

Annual report (required of 40 CFR 262.83(g) 3 years from the date the HW was accepted by 40 CFR

Record* Citation Retention Time** Citation primary exporters of HW) the initial transporter 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

Initial Accumulation Points

The generator at an IAP must ensure that the following documents are kept on file for the safe management and handling of hazardous wastes in the generating area.

• SDSs and

• Facility or MICT inspection reports.

Hazardous Waste Accumulation Site

Because the accumulation site is restricted by time and EPA requires that the generator have on file written documentation (Bldg 29) for the removal of hazardous waste, the accumulation site must retain DD Form 1348-1a as (Bldg 29) in addition to the following:

• Weekly inspection logs,

• Hazardous waste profile,

• Hazardous waste training records,

• Waste analysis results and,

• SDSs.

Asset Management - Environmental

As the Office of Primary Responsibility for the management of the RCRA program at Avon Park AFR, the Installation Management - Environmental Flight is responsible for ensuring that appropriate records are maintained at IAPs and HWAS. This organization is required to maintain extensive files documenting hazardous waste management. In addition to maintaining training records and EPA reports, the Environmental Flight will maintain the following:

• Operating permits,

• Annual reports,

• Accident/Incident reports,

• Biennial reports, and

• Hazardous waste funding reports.

Reporting

The State of Florida and EPA under RCRA require hazardous waste generators and TSDFs to submit certain reports regarding the types and quantity of wastes generated, environmental releases, and manifesting irregularities. This section discusses these reports and organizations tasked with reporting.

Release Report/Incident Report

RCRA regulations in 40 CFR 265.56 require hazardous waste generators and TSDFs to report releases, fires, or explosions involving hazardous wastes that could threaten human health or the environment outside the installation.

When required, notification of the National Response Center should not be delayed. 40 CFR 265.55 requires immediate notification if an incident could endanger human health or the environment off-installation. 40 CFR 265.196 requires notification within 24 hours of any releases from tanks unless the exception criteria are met.

RCRA regulations in 40 CFR 265.93 require hazardous waste generators and TSDFs to provide written notice to the appropriate EPA Regional Administrator within 7 days of confirming a significant increase in concentrations of hazardous waste or hazardous waste constituents above background levels in the groundwater or confirming any significant decrease in the pH of the groundwater. Within 15 days after notifying EPA that the facility may be affecting groundwater quality, the owner/operator of the facility is also required to develop and submit to the appropriate Regional Administrator a specific plan for a groundwater quality assessment program at the facility.

Exception Reports

If the Environmental Flight does not receive a copy of the manifest with the signature of the owner, operator, or authorized representative of the designated facility within 35 days of the date the waste was shipped off-installation, the status of the waste must be determined. The transporter and the TSDF must be contacted to confirm that the waste shipment was in fact delivered and accepted and to obtain a copy of the manifest.

If the waste was not delivered or accepted, the location of the waste must be determined. The installation continues to be liable for its hazardous waste until the waste is no longer hazardous. If the Environmental

Flight does not receive a copy of the closed manifest within 45 days of the date the waste was accepted by the initial transporter, the organization must submit an exception report to the state environmental agency or the EPA Regional Administrator.

Discrepancy Reports

Significant manifest discrepancies between the quantity or type of waste designated by the installation on the manifest and received by the TSDF should be resolved as soon as possible. Significant discrepancies in quantity are, for bulk waste, variations greater than 10% in weight, and for batch waste, any variation in piece count such as a discrepancy of one drum in a truckload. Significant discrepancies pertaining to the type of waste would be obvious differences, discovered by the TSDF, between the type of waste described on the manifest and the type of waste actually received, as well as differences discovered by inspection or waste analysis.

Upon discovering a significant discrepancy, the TSDF must try to reconcile the discrepancy with the transporter and the installation. All parties should work together to determine the true quantity and type of waste. Hazardous waste generators should document discrepancy-related telephone conversations and keep copies of all correspondence and waste analyses concerning the discrepancy.

If the discrepancy is not resolved within 15 days of receiving the waste, the TSDF must immediately submit a discrepancy report to EPA. The discrepancy report must include:

• A letter describing the discrepancy and attempts made to reconcile the discrepancy and

• A copy of the manifest or shipping paper at issue.

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

Avon Park AFR maintains a hazardous waste stream inventory for every hazardous waste stream generated (found within the HW Module of the EESOH-MIS Program – See Appendix B). The Environmental Flight is the office of primary responsibility for the Avon Park AFR hazardous waste stream inventory. Avon Park AFR will not handle, store, transport, dispose of, or inventory non-DoD owned hazardous wastes or materials except as authorized.

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 Safety Data Sheet (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 the wastes that have been 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

Avon Park AFR will ensure that all wastes are properly characterized and classified as either hazardous or non-hazardous wastes in accordance with the Avon Park AFR WAP (see Appendix A). Hazardous wastes will be characterized on the Hazardous Waste Profile. Information from the profile will be used by the Environmental Flight to maintain and update the hazardous waste stream inventory. The hazardous waste program manager is responsible for quantifying all hazardous waste streams for the hazardous waste stream inventory.

Hazardous waste generating activities will identify and separately document wastes that are classified as non-hazardous due to solid or hazardous waste exclusions or are recycled and are not subject to the generator waste determination requirements of 40 CFR 262.11 (e.g., lead-acid batteries that are being reclaimed, used oil that is burned for energy recovery, or scrap metal that is recycled). Land disposal restriction regulations published in 40 CFR 268.7(a)(6) require a generator that is managing a land disposal restricted waste that is excluded from the definition of hazardous or solid waste or exempt from Subtitle C regulations under 40 CFR 261.2261.6 to document the waste, its exclusion or exemption, and the disposition of the waste.

Waste Analysis Plan

The Avon Park AFR WAP (Appendix A) was developed by the environmental flight to provide a systematic approach for obtaining chemical analysis for generating activities. Additionally, the WAP assists with quality control procedures for identifying new waste streams at Avon Park AFR.

The WAP, as required by 40 CFR 264.13, 268.7, and 270.14 applies to all Avon Park AFR hazardous waste streams that are transferred to DRMS. To comply with federal and state requirements, the WAP contains the procedures for identifying and evaluating hazardous waste streams in order to complete a hazardous waste profile sheet on each waste stream.

The WAP also provides detailed procedures for the following activities:

• Obtaining physical and chemical analysis from waste generating activities,

• Selecting parameters for analysis,

• Selecting waste sampling methods,

• Documenting sampling collection and transport,

• Identifying analytical methods,

• Selecting laboratory facilities,

• Reevaluating waste streams,

• Updating waste inventories, and

• Revising WAP directives.

The Waste Stream Inventory provides a current inventory of wastes routinely generated at Avon Park AFR. These wastes have been characterized primarily through sample analysis and process knowledge.

To determine the characteristic of an unknown material, generators should follow the guidance provided in this section.

Waste Identification Procedures

The overall characterization process for hazardous waste involves waste identification, waste description, and waste quantification. These steps naturally occur after generation and prior to disposal. Waste Characterization Guidance Sequence provides the AFPAM 32-7043 guidance for determining waste characterization.

Hazardous waste identification will be determined as specified in 40 CFR 261. If a material is determined to be a waste and has not been excluded from regulation, the material may be designated as a characteristic hazardous waste (e.g., ignitable, corrosive, reactive, or toxic), a listed hazardous waste, or a mixture of a listed hazardous waste and a solid waste. The identification may be determined by one of two methods:

• The generator’s knowledge of the process generating the waste or

• Analysis of a representative sample of the waste being generated.

Analytical testing is not normally required for unused commercial chemical products or laboratory chemicals in their original containers. If analytical testing is needed, the generator will contact the hazardous waste program manager, who will then notify the Environmental Flight to request that the waste be analyzed. The Installation Management -Environmental Flight will ensure that a sample is collected and will forward it to the appropriate laboratory for analysis. The hazardous waste program manager will determine whether the generator’s knowledge of the waste is sufficient to characterize the waste. If sampling and analysis is required, all sampling and analysis costs will be funded from the installation environmental compliance funds. Sampling and analysis will be conducted in accordance with the requirements specified in EPA SW-846 and the Avon Park AFR WAP. Analytical Methods and SW- 846 Numbers Table provides the analytical methods and SW-846 numbers. The sample, along with its appropriate label (Example of a Sample Label) and its chain-of-custody form (Example of a Chain of Custody Form), is delivered to an assigned laboratory. Sample analysis results are received by RMFI, who will evaluate the results to determine whether hazardous waste criteria have been met. The results will be forwarded to the hazardous waste program manager at Avon Park AFR, who will work with the hazardous waste coordinator and DRMS to dispose of the material.

Travis Hickey Waste Stream Inventory should be referenced and not included in this plan.

Waste Characterization Guidance Sequence

Analytical Methods and SW-846 Numbers

Analytical Methods SW-846 Method Numbers TCLP Metals SW-6010, 7470 (Hg) TCLP Volatiles SW-8240 TCLP Semivolitiles SW-8270 Ignitability SW-1010 Extraction SW-1311 Extraction preparation for flame/ICP SW-3010 Extraction preparation for furnace SW-3020 Extraction preparation for oils/grease SW-3040 Extraction preparation for sludge SW-3050 Total organic halides SW-9020 Trichloroethane SW-8010, 8240

Source: EPA Test Methods for Evaluating Solid Waste, Physical Chemical Methods (EPA SW-846).

Example of a Sample Label

Date

Sampler

Sample Site

Point of Contact

Time Sampled

Field Specifics

Example of a Chain of Custody Form

598 RANS/RMFI Sample No.

Avon Park, FL

Chain-of-Custody Form

Sample Description

Sample Point

Collector’s Name Date/Time Sampled

Amount Collected Preservation

PRECAUTIONS:

CHAIN OF POSSESSION:

Received From

Received By Date/Time Received

Name of Receiving Organization

Comments

Received From

Received By Date/Time Received

Name of Receiving Organization

Comments

Received From

Received By Date/Time Received

Name of Receiving Organization

Comments

Waste Description

Once analytical results are received, these results must be interpreted to determine whether a waste stream is hazardous. The Hazardous Waste Program Manager will determine the characteristics of the waste based on the results received. This information will be used to complete the hazardous waste profile and to determine the proper labeling for the containers.

Waste Quantification

To determine how much waste is generated, the Avon Park AFR hazardous waste program manager documents the amount of waste generated by the facilities (at the IAPs) and transferred to the HWAS.

This information is compared to the amounts recorded on the hazardous waste manifests and then maintained in an Excel spreadsheet.

Hazardous Waste Sampling and Frequency

When collecting samples to be analyzed, the Hazardous Waste Program Manager must ensure the samples are sampled in accordance with the ASTM International standards specified by EPA and provided in Representative Sampling Method Protocol Table. Additionally, samples must be collected in appropriate containers, have adequate preservation if required, and adhere to recommended holding times.

Suggested information with regard to these specifications are outlined in the Avon Park AFR WAP. All sample containers and equipment must be free from contamination before use and must be decontaminated after use. Decontamination procedures are often specified by the manufacturer; however, the hazardous waste manager will ensure that proper decontamination procedures are carried out for all equipment that will be reused. If possible, disposable samplers such as Coliwasas are recommended.

Representative Sampling Method Protocol

Sample Type EPA Protocol Extremely viscous liquids ASTM Standard D140-70 Crushed or powdered materials ASTM Standard D346-75 Soil/rock-like material ASTM Standard D420-69 Soil-like material ASTM Standard D1452-65 Ash-like material ASTM Standard D2234-76 Containerized liquid wastes SW-846 COLIWASA Procedure Liquid wastes in pits, ponds, and similar reservoirs SW-846 Pond Sampler

PPE should be worn that is appropriate for the waste type to be sampled (i.e., chemical safety goggles, impervious gloves, boots, overalls, and/or respirators). A minimum of Level B protection must be worn when sampling unknown wastes

Low-volume waste streams (those that generate three or less 55-gal drums per year) will be evaluated at least every 3 years unless there has been a process change that would dictate a more frequent evaluation.

High-volume waste streams (those that generate four or more 55-gal drums per year) will be evaluated at least annually.

Sampling Techniques

The hazardous waste program manager will ensure that personnel that accomplish sampling do the following:

• ASTM procedures are being followed,

• Representative samples are being taken,

• Decontamination procedures are effective,

• Sample collection is documented, and

• PPE is effectively utilized.

This training will be provided on an as needed basis for new staff coming into the program.

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 rusting, no sharp-edged creases or dents, no bulging heads, and no severe structural defects.

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

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

• 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 maintained at all times 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

Since most wastes are likely to be transported off-installation for disposal, they will normally be stored in DOT-approved 55-gal drums. These drums will be selected based on the DOT Hazardous Materials Table found in 49 CFR.

Hazardous wastes are stored in the HWAS and accumulated in the IAPs at Avon Park AFR. Quantities of waste products may be stored in approved bulk storage tanks or drums. To minimize the threat of wastes released to the environment, containers should be placed on impermeable surfaces or within containment systems that are capable of preventing environmental contamination due to container overfilling or leaks.

Containers will not be placed on dirt, sand, gravel, or grass surfaces. Additionally, containers or hazardous waste storage tanks should not be located near floor drains, sanitary sewers, or storm water sewers. As a general rule, containment systems should be designed to contain the volume of the largest container or 10% of the volume of all containers, whichever is greatest. In addition, it is often recommended that concrete containments are treated with a sealant to prevent spills from absorbing onto or passing through the containment.

The containment systems should be sloped to allow liquids resulting from releases to drain into a sump or containment vessel. All hazardous wastes will be segregated at the IAP/CAP. Different waste streams are accumulated in separate containers at the IAP and HWAS. For incompatible wastes, segregated containment may be accomplished by using either separate containment areas or by means of separately diked areas or sloped containment to separate sumps. To prevent mixing of hazardous wastes with rainwater collected in sumps or containment areas, pumping or draining the area should be performed as soon as possible.

Precautions must be taken to prevent accidental ignition or reaction of ignitable or reactive waste.