Attach__No__1B_-_Consolidated_HWMP_Playbook.pdf

Hazardous Waste – “Plan Phase” – Overview

Introduction to the Hazardous Waste (HW) Playbook

HW Playbook Purpose, Goals and Scope

In accordance with AFMAN 32-7002, Environmental Compliance and Pollution Prevention and PAD 12- 03, Implementation of Enterprise-Wide Civil Engineer Transformation, the HW Management Program must meet Environmental Management System (EMS) requirements and follow the Plan, Do, Check, Act (PDCA) framework. In lieu of a federal requirement, AFMAN 32-7002 acts as the main driver for the HW Management Plan, and the HW Playbook serves as a supplement to this plan.

Following the EMS PDCA framework, the HW Playbook is organized according to the table in the Organization of HW Playbook section below.

Limitations: This playbook does not replace, supersede, or circumvent existing DoD or Air Force policy.

If conflicting, Federal, state, local or Outside the Continental United States (OCONUS) regulations and Resource and Conservation Recovery Act (RCRA) permit conditions take precedence over the guidance in this playbook.

This playbook references the Enterprise Environmental, Safety, and Occupational Health Management Information System (EESOH-MIS).

Playbook Roles

The major roles involved in the HW Playbook program are AFCEC, HW Manager, Initial Accumulation Point (IAP), Defense Logistics Agency (DLA), the shop, and the generating activity. Detailed information about their responsibilities are located in the Element I Ongoing functions narratives.

Organization of HW Playbook

The organization of the HW Playbook follows the EMS PDCA cycle in the table below:

Name of Playbook Section Alignment to EMS (Plan, Do, Check, Act)

HW Overview Plan Element I AFCEC Functions Plan

HW Manager Responsibilities Do Shop/Hazardous Waste Generator Responsibilities Do DLA Responsibilities Do IAP Responsibilities Do Accumulation and Handling Requirements Do Post Award Monitoring Check HW Management Plan Plan Reporting Do Training Do

Element II HW High Level Do

1.0 Manage Regulated Waste Generating Activity Do

1.3 Characterize Waste Do

1.3.5 Conduct Sampling and Analysis Do

1.3.11 Consider Disposal Vehicle Do

1.5 Establish Regulated Waste IAP/HWAS

Manager and Site

Do

1.6 Determine Means of Collection Do

2.0 Accumulate and Handle Waste Do

3.0 Determine Disposal or Recycling Method Do

3.8 Conduct Non-DLA Disposal Do

3.9 Conduct DLA Recycling/Disposal Do

Monitoring, Measurement and Corrective Actions Check Management Review and Continual Improvement Act

Introduction to the HW Program

About the HW Program

Inherent in the mission of the Air Force are the associated environmental responsibilities of protecting human health and the environment, and ably managing the natural resources whose care has been entrusted to the Air Force. In accordance with RCRA, the Air Force will have a program in place to reduce the volume and toxicity of waste generated. The program considers waste avoidance at all stages of a material’s lifecycle, first through source reduction, e.g., chemical substitution, process change, and other techniques to reduce generation of hazardous waste. When a material with environmental risk is used, procure minimal quantities to minimize surplus quantities. If the use of such materials is unavoidable, evaluate all excess or waste material for reuse or recycling whenever feasible. As a last resort, spent material or waste that is not reused or recycled must be disposed of in an environmentally safe manner, consistent with the requirements of all applicable laws, including RCRA. HW management interrelates, or has the potential to interrelate, with the management of many other environmental programs (e.g., air, water, natural resource programs). In addition, the consequences of mismanaging the HW program can affect the health and safety of an installation’s workforce.

The HW Program defines hazardous waste as any solid waste defined as a hazardous waste pursuant to 40 CFR part 261.3 or authorized state or host nation rules and regulations (this definition is in accordance with AFMAN 32-7002).

Purpose of the HW Program

The HW Management Plan includes the installation activities and infrastructure required for ongoing management, handling, and disposal of hazardous waste. The purpose of the HW program is to manage the documentation and disposal of hazardous waste to: (1) support Air Force missions; (2) protect the safety and health of personnel on Air Force installations and communities surrounding Air Force installations by ensuring proper documentation and disposal of hazardous waste; (3) and maintain Air Force compliance with environmental requirements for hazardous waste disposal in accordance with the EMS framework and PDCA cycle.

HW Program Specific Mission and Goals

Mission Statement: The HW program manages waste in accordance with applicable regulations to minimize negative impacts to the AF mission. The HW program is an asset management approach to maximize performance and minimize cost associated with waste generation and disposal.

The HW program accomplishes the following primary goals:

• Goal #1: Fully and accurately characterize all waste streams o Performance Objective/Task: Characterize 100% of waste streams

• Provide sampling and analysis services

• Maintain current waste stream inventory

• Establish defensible generator knowledge documentation

• Eliminate excessive/superfluous sampling and analysis

Key Performance Indicator (KPI): % of waste streams characterized and current o Performance Objective/Task: Reduce sampling and analysis costs

• Cost effectively characterize waste streams

KPI: Sampling cost per waste stream (waste streams entering HW process flow)

KPI: Percentage of waste streams characterized by user knowledge

• Total # of waste streams

• # of waste streams characterized through user knowledge

• # of waste streams characterized through chemical analysis o Performance Objective/Task: Complete and update Waste Analysis Plan

• Conditionally exempt small quantity generators (not applicable)

• Goal #2: To enable and sustain compliant sites and activities o Performance Objective/Task: Eliminate Enforcement Actions through regulatory compliance

• Reduce # of findings from Stage II and Stage III (Internal/external audit) assessments

• Reduce # of findings per regulatory inspections/audits annually

• Goal #3: Optimize cost-effective program management o Performance Objective/Task: Reduce HW management and disposal costs

• Consolidating Contracted Services through Strategic Sourcing which will streamline HW services contracts

KPI: # of HW Management Service contracts KPI: # of HW DLA Disposal contracts KPI: # of HW Non-DLA Disposal contracts KPI: # of HW Analytical contracts

• Develop centralized performance work statement

• Amount of Environmental Quality (EQ) funding programmed for HW contracting KPI: Cost per pound to include disposal, management and analytical services

• Reduce HW disposal and management costs by 2% per year (2010 baseline)

• Eliminating permits/Treatment Storage Disposal Facility (TSDFs)

• Goal #4: To provide safe infrastructure and services to minimize ESOH risk o Performance Objective/Task: Efficiently and effectively operate a centralized HW accumulation facility and program o Performance Objective/Task: Ensure centralized HW storage facilities are on Civil Engineer (CE) real property records, if applicable

• For centralized HW storage, assure real property assigned square footage if not previously assigned

KPI: Plans current and annually approved and updated by Environmental Safety and Occupational Health Council (ESOHC)

• Complete HW Management Plan

• Complete HW contingency plan

• Ensure HWAS has appropriate emergency response supplies/equipment

• Support and promote the safe transfer of HW on the installation

• Goal #5: To provide adequate training to the HW workforce o Performance Objective/Task: Ensure 100% of accumulation point managers and alternates have received appropriate awareness-level training, and baseline and refresher RCRA required training

• Document HW training of accumulation point managers and alternates

• Ensure HW training is accomplished on-time

• Goal #6: Establish and sustain effective tracking activities to manage all HW generated by the installation o Performance Objective/Task: 100% of base EESOH-MIS deployment to Full Operating Capability (FOC) at appropriate facilities. 100% FOC implies all Shops, storage areas, accumulation points and waste stream inventories are tracked within the new system, the Legacy system is shut down, all key personnel are trained on its use, and that the IT system is capable of performing the following functions:

• Fix latest critical HW BCRs approved for funding

• Ensure capability to perform automatic disposal transactions with DLA system

• Legacy system shutdown occurs when all transactional data is closed out within the Legacy system (see EESOH MIS Implementation Plan for HW) o Performance Objective/task: Optimize environmental management and reporting using the standard enterprise HW tracking system

• Goal #7: To provide effective cradle-to-grave disposition of HW o Performance Objective/Task: HW minimization/Recycling Services (support HW Goal

#5 to reduce hazardous waste)

• At the AF level, sustain 50% decrease in HW disposal from recurring operations (1996 baseline)

• 2% (overall AF 10% by 2020, based on 2010 baseline) per annum decrease in recurring HW disposal (baselines established year-by-year to ensure resources expended each year on a cost effective basis to divert HW (through annual elimination/recycling services)

This metric applies only to large quantity generators or equivalent for

OCONUS

Reduction implies source reduction and diversion (recycling, etc.)

• Central Accumulation/Consolidation

• Goal #8: To effectively and efficiently leverage existing DoD disposal mechanisms (e.g., DLA) o Performance Objective/Task: Capitalize on standard levels of service and economy of scale for management services secured through DLA disposal contract vehicles

Drivers of the HW Playbook

Amongst current key drivers are the RCRA, which drives Waste Minimization certification requirements;

Clean Air Act; Emergency Planning & Community Right-to-Know Act (EPCRA); Executive Order 13834, Efficient Federal Operations; AFMAN 32-7002, Environmental Compliance and Pollution Prevention; and PAD 12-03 Implementation of Enterprise-Wide Civil Engineer Transformation regarding the following specific components:

• 1.1 The AFCEC will manage the EQ and environmental planning function (EPF) responsibilities formerly located at MAJCOMs to include COCOM environmental support at USAFE and PACAF

• 2.1.3.1: AFCEC: Plans, organizes, directs and controls the Air Force EQ programs of the installations on behalf of the AF/A7C and the MAJCOMs. Provides support for environmental compliance, conservation and P2 programs

• 2.1.5.1: Installation: retains local compliance management of the installation environmental compliance, conservation, P2 programs to ensure compliance with all federal, state, and local laws and regulations. Accountability and primary responsibility for environmental compliance will remain at the installation

• 2.1.3.2: AFCEC supports and maintains the effective implementation of the Air Force Environmental Management System (EMS) to include coordination with necessary mission support areas

• 2.1.5.2: Installation CC’s will continue to chair installation-level ESOHC and provide oversight of the installation EMS

Additionally, the ISO14001 International Standard for Environmental Management Systems – Requirements with guidance for use provides guidance on how the HW program should be established, implemented, and maintained to operate under the EMS framework.

Hazardous Waste – “Plan Phase” – Element I: AFCEC Functions

Introduction Narrative

This narrative has been added to the HW Playbook in order to comply with the PAD 12-03 Implementation of Enterprise-Wide Civil Engineer Transformation, Section 1.1, “AFCEC will manage the EQ… function responsibilities formerly located at MAJCOMs to include COCOM environmental support at USAFE and PACAF… All remaining MAJCOM CE environmental functions and responsibilities will be transferred to the AFCEC.”

Using the Programming Plan (P-Plan) Revision 1 for Implementation of Enterprise-Wide Civil Engineer Transformation (PAD 12-03), Volume 2 as a basis, this narrative lists the offices of primary responsibility (OPRs) within AFCEC that execute AFCEC’s Hazardous Waste Management Plan (HMWP)-related tasks. For tasks for which the installation is the OPR, the appropriate AFCEC offices of coordinating responsibility (OCRs) have been listed.

AFCEC has the following ongoing responsibilities to maintain a successful HW Management program:

• EMS Program Management – OPR: AFCEC/CZCA o Ensure that the HW Management program is an Environmental Management System

(EMS)-based process with the goal of reducing risks to the environment, by ensuring compliance, preventing pollution, and looking for ways to continually improve (For additional information, refer to the EMS Playbook on the Civil Engineer [CE] Portal)

• Obtain, renew, update, and maintain permits – OPR: AFCEC/CZO IST o Verify required permits are needed o Prepare the permit application and renewal documents; document return receipt from regulators o Submit permit application and pay associated fees o Provide specialize resources to monitor installation activities to evaluate permit compliance, as required o Complete trend analysis o Propose to installation corrective actions to fix-compliant situations o Draft permit application in coordination with installation, consistent with regulatory requirements o Provide consultant or contracted assistance o Collect and review public comments o Program corrective action in Automate Civil Engineer System-Project Management

(ACES-PM) as required o Identify root causes for permit non-compliance o Provide support for installations implementing permits

• Develop & maintain Hazardous Waste Management Plan – OPR: AFCEC/CZO IST o Develop Air Force-wide template for HW plans o Verify plan meets installation needs o Analyze trends in plan problems and short falls o Program projects in Automated Civil Engineering System-Project Management

(ACES-PM) as required o Evaluate plan problems and short falls to determine if they require corrective actions

• Performance measurement, monitoring and reporting – OPR: AFCEC/CZCA o Identify reporting requirements (Air Force and regulatory) o Identify Activity Management Plan (AMP), unique Key Performance Indicator (KPI), and Performance Measurement Target (PMT) data requirements o Develop proposed KPIs and PMTs o Identify KPI metrics (both those required for HHQ reporting as well as those required for base-level management and tracking) o Review installation and Air Force Civil Engineer Center (AFCEC) KPI, and PMT data into applicable AMPs and other databases o Verify performance measurement data with installation, as appropriate o Take corrective action to adjust, as needed o Develop contract to collect data to support KPIs and PMTs, as needed o Provides input to Contracting Officer’s Technical Representative (COTR) o Ensure and execute Sampling Analysis Monitoring (SAM) contracts meet installation expectations and requirements o Validates SAM reaching out to HW Manager as needed and other contract meets requirements o Program and validate potential project requirements o Work with installation to identify SAM requirements o Prepare programming planning documents to fix/improve performance o Verify data collected and reported o Perform trend analysis

• Perform required recordkeeping – (Although the installation has primary responsibility, AFCEC/CZO IST, AFCEC/CZTQ and AFCEC/CZCA have coordinating responsibility) o Identify AFCEC specific recordkeeping requirements o Collect AFCEC data, documents and maintain records/files/databases o Verify HW records are accurate and current o Provide installation appropriate records generated by AFCEC

• Receives & provides compliance driven training (Resource Conservation Recovery Act

(RCRA) Department of Transportation (DOT) and Occupation Safety and Health Administration (OSHA)) – OPR: AFCEC/CZCA o Coordinate with base to identify training needs and options to accomplish training o Develop training material in house or via contract, as required o Review feedback from base o Prepare adjustments and updates to training provided by AFCEC (in-house or contract) o Identify source of training o Provide training in house or via contract, as required o Adjust and update training, as needed o Review training for improvements with AFCEC IST o Attend Air Force Institute of Technology (AFIT) training o Train installation Enterprise Environmental Safety and Occupational Health

Management Information System (EESOH-MIS) HW users

• Perform auditing (EMS Audit, recurring compliance assessments) – (Although the installation has primary responsibility, AFCEC/CZO IST, AFCEC/CZTQ and AFCEC/CZCA have coordinating responsibility) o Plan and schedule augmentation support for Stage III (AFCEC only) o Participate in IG/ Stage III management system audits (AFCEC only) o Input Stage III audit findings into Inspector General (IG) database (AFCEC only) o Verify Audit activity completed on schedule o Support installation to make correction action as needed o Develop management action plan and implement corrective actions as needed o Augment Stage II Audit, if requested by base o Analyze findings and determine trends o Generate reports o Perform trend analysis o Update or adjust available information as needed

• PPBE requirements – OPR for Planning: AFCEC/CP; OPR for Programming, Budgeting and Execution: AFCEC/CZCP o Communicate project scope, cost, and year required to AFCEC o Verify requirement is properly programmed o Execute current FY program o Plan and program for requirements o Identify shortfalls and alert AFCEC/management as needed o Execute base-specific recurring and selected non-recurring requirements (e.g., permit fees, SAM, supplies, TDY) o Verify current and future year funding requirements are in the Air Force program o Work with installation to insure funding needs are identified; Ensure regulatory requirements and other requests are funded as scheduled/planned o Develop budget and execution plan o Ensure programming meets installation needs o Identify Planning, Programming, Budgeting, and Execution (PPBE) process improvement o Estimate funding amounts based on historical or other cost estimates; evaluate if funding was adequate or requires adjustment o Program funding requirements in ACES-PM, etc.

o Verify contract support meets installation needs o Identify proposed changes to Environmental Quality (EQ) program funding matrix o Develop Air Force-wide Integrated Priority List (IPL) o Validate installation EQ funding request o Prepare and identify EQ eligible funding trend, categorical analysis, and recurring and non-recurring funding requirements o Execute centrally-managed EQ support contracts

• Review, analyze, and implement regulatory requirements / Provide regulation and legislation support – OPR: AFCEC/CZO REG/LEG o Determine operations impacted by identified legislative or regulatory action that impact mission operations o Review and provide comments on proposed regulations through and in coordination with AFCEC; will coordinate with HW manager as needed o Identify potential funding requirements resulting from regulatory changes o Implement processes to comply with new regulations applicable to AFCEC

Installation Support Team (IST) o Review and submit Air Force comments to proposed regulations o Follow through on legislation or proposed rules as needed, e.g., were comments accepted and addressed o Analyze impact of pending legislative and regulatory actions o Identify applicable regulations (federal, state, local, Final Governing Standards [FGS], or Department of Defense [DoD]) for installation o Program funding needs for installation o Coordinate on and provide input to Overseas Environmental Baseline Guidance

Document (OEBGD) o Organize process review of proposed regulations impacting installation o Provide guidance to installations on new regulation or changes in regulations o Coordinate on and develop FGS when AF is deemed executive agent o Check new regulatory announcements; advise installation, as needed o Review and develop Air Force policy and guidance o Identify required actions to implement changes to laws and regulations o Update Air Force policy and guidance to implement changes to laws and regulations o Evaluate application for Continental United States (CONUS) and Outside the

Continental United States (OCONUS) and the different mission impacts before updating policy o Identify required actions to implement changes to laws and regulations

• Guides regulatory inspections – (Although the installation has primary responsibility, AFCEC/CZO IST, AFCEC/CZTQ and AFCEC/CZCA have coordinating responsibility) o Review and analyze regulator’s report o Coordinate final issues with regulator for close-out

• Perform COR/COTR responsibilities (Contracting responsibilities) – OPR:

AFCEC/CZCP

o Provide technical review/evaluation of deliverables o Attend contract kick-off meetings o Identify AFCEC-managed contracts/contractors that will require COR/COTR support with HW impacts and ensure HW requirements are inserted into the appropriate contract vehicles o Provide technical review/evaluation of deliverables o Improve and adjust processes as needed o Attend contract kick-off meeting o Complete monthly certificate of service if applicable o Review contractor work is performed per contract o Ensure requirements are identified and, when necessary, modified so as to obtain desired performance in future contracts o Approve invoices in Wide Area Workflow (WAWF) o Validate contractor payments on time o Escort and coordinate access for contractors for EQ-related contracts o Contractor site access not delayed o Coordinate contractor visit with installation Point of Contact (POC) o Review contract and contract performance with respect to (WRT) HW requirements o Work with appropriate contracting offices (AFCEC, Center of Excellence [CoE]) to ensure contractors whose work can create HW impacts and who must comply with the Air Force and installation HW requirements identified within their contracts o Provide standard HW contract language for installations’ use in unified facilities guide specifications format

• Use EESOH-MIS for HW management and tracking – (Although the installation has primary responsibility, AFCEC/CZO IST, AFCEC/CZTQ, AFCEC/CZCP, and AFCEC/CZCA have coordinating responsibility) o Collect EESOH-MIS requirements and post to system o Advocate, communicate, and train base-level users on EESOH-MIS o Identify and approve EESOH-MIS change requests o Program requirements (AFCEC only) o Validate data is consistent, accurate, and complete o Participate in the EESOH-MIS HW FWG as required o Assist in the maintenance of data o Monitor effectiveness of EESOH-MIS o Analyze and decompose EESOH-MIS requirements (AFCEC only) o Schedule and conduct Functional Working Group (FWG) meetings and record minutes (AFCEC only) o Lead the EESOH-MIS HW FWG (AFCEC only) o Brief panels and PMO on EESOH-MIS requirements (AFCEC only) o Implement required changes for EESOH-MIS o Improve data collection quality within EESOH-MIS

• Manage/use environmental IT products – (Although the installation has primary responsibility, AFCEC/CZO IST, AFCEC/CZTQ, AFCEC/CZCP, and AFCEC/CZCA have coordinating responsibility) o Identify, document and report revisions to IT systems (AFCEC only) o Assist in the maintenance of IT system data o Validate IT system meets needs o Program IT requirements o Report requirements for changes to IT system o Identify authoritative sources of data (AFCEC only) o Coordinate and review annual program requirements with AFCEC using AFCEC-directed IT systems o Communicate and promote IT tools to senior leadership o Ensure accessibility and sharing of data within IT systems at all levels

• Hazardous Materials/Hazardous Waste Panel – OPR: AFCEC/CZTQ o Evaluate panel and governance process effectiveness o Identify appropriate Hazardous Material (HM)/HW panel membership o Participate in HM/HW panel representing base and region o Represent enterprise and installation issues appropriately o Chair the HM/HW panel

• Provide technical environmental assistance – OPR: AFCEC/CZTQ and AFCEC/CZCA o Participate in the semi-annual Environmental Quality (EQ) Data Call (used to develop the ESOH-EMR and Defense Environmental Programs Annual Report to Congress

[DEPARC])

o Forecasts data call requirements (e.g., annual Defense Environmental Program Annual Report to Congress [DEPARC]) o Verify data for DEPARC o Assemble and prepare HHQ data call response o Reviews projects for environmental concerns and regulatory requirements o Plan for time and resources to collect data, write, edit, and route reports (e.g. AnSR) o Provide technical support to installation on spills and releases as needed o Reviews Statement of Work (SOW) for compliance with HW requirements o Prepare contract for extended spill response o Research technical issues for installation

• Characterize all waste streams – (Although the installation has primary responsibility, AFCEC/CZO IST and AFCEC/CZTQ have coordinating responsibility) o Obtain contract for sampling and analysis support (AFCEC only) o Conduct annual waste profile review and update o Generate waste profiles o Interpret sampling and analysis results o Document generator knowledge

• Manage site accumulation of all hazardous – (Although the installation has primary responsibility, AFCEC/CZO IST and AFCEC/CZTQ have coordinating responsibility) o Provide guidance on organizationally-managed HWAS o Manage and maintain HW support contract (obtaining contract and Quality

Assurance Evaluator (QAE)) o Manage on-site QAE oversight function for HW support contract (obtaining contract and QAE)

• Operate permitted TSD facilities (if required) - (Although the installation has primary responsibility, AFCEC/CZO IST and AFCEC/CZTQ have coordinating responsibility) o Manage and maintain Treatment, Storage, or Disposal Facility (TSDF) support contract, as required o Ensure facility complies with permit requirements o Ensure HW is managed IAW permit requirements

• Arranges HW disposal/recycling and directs HW turn-in – (Although the installation has primary responsibility, AFCEC/CZO IST and AFCEC/CZTQ have coordinating responsibility) o Manage the payment and reimbursement for HW disposal and recycling costs after HW Managers have correctly set up the established new sites (AFCEC only) o Forecast HW types and estimated volumes for DLA contract by AFCEC IST o Develop waiver request for non-Defense Logistics Agency (DLA) waste disposal contract o Approve the use of non-Defense Logistics Agency (DLA) waste disposal contract

(AFCEC only) o Manage and maintain disposal/recycling contract o Approve payment to DLA o Track customer reimbursement o Contract for non-DLA items o Assists with disposal agency, i.e., Defense Logistics Agency (DLA), on disposal facility inspections when requested o Advises generators of HW transportation requirements per AFCEC IST o Conduct inspection of non-DLA off-site TSD facility used by the base per AFCEC IST

• Internal and External Communications – OPR: AFCEC/CZCA

Hazardous Waste – “Do Phase” – Element I: Hazardous Waste Manager Responsibilities

In accordance with the PAD 12-03 Implementation of Enterprise-Wide Civil Engineer Transformation and the Programming Plan (P-Plan) Revision 1 for Implementation of Enterprise-Wide Civil Engineer Transformation (PAD 12-03), Volume 2, this narrative describes the ongoing responsibilities of the Hazardous Waste (HW) Manager on the installation.

Hazardous Waste (HW) Managers have 8 main, ongoing responsibilities to maintain a successful Hazardous Waste Management Program:

• Interface with Generators (to include training) o Implement procedures (HW Plan, etc.) to ensure/track installation operations comply with plan and generators maintain up-to-date waste stream information and profiles to include implementing the AF-approved automated HW tracking system, Enterprise Environmental, Safety, and Occupational Health Management Information Service

(EESOH-MIS)

o Waste Analysis Plan: Addresses sampling procedures on the installations, who performs sampling, and how often o Collect samples, conduct analysis, process and ship samples o Develop consolidated list of installation waste streams o Generate waste profiles o Maintain waste profiles and update in EESOH-MIS o Participate in work order (AF Form 332) and process authorization review to identify new or changed waste streams o Visit workplace process to identify waste streams installation-wide o Interpret analytical results or use product knowledge to characterize waste stream o Document generator knowledge o Validate Sampling Analysis, Monitoring (SAM) and other contract meets requirements o Identify and ensure that appropriate personnel needing training are adequately trained by identifying and scheduling training requirements and verify training was completed o Review training for improvements and effectiveness o Attend Air Force Institute of Technology (AFIT) WENV 521, Hazardous Waste

Management course o Provide training as necessary when Air Force Civil Engineering Center (AFCEC) availability impacts ability for timely training o Maintain training records/documentation o Identify users and provide access to IT systems required by base o Advocate, communicate, and train base-level users on EESOH-MIS

• Interface with Regulators (except Outside the Continental United States (OCONUS)) o Act as the liaison office for environmental HW compliance issues with regulatory agencies, In Accordance With (IAW) applicable policy o Identify issues (including significant Environmental Management System (EMS) aspects) and propose corrective actions Implement correction actions to fix non-compliant situations o Identify project requirements to correct deficiencies o Determine operations impacted by identified legislative or regulatory action o Review and provide comments on proposed regulations as needed by AFCEC o Review/update and coordinate notification of HW activity o Brief local leadership and management as needed o Implement processes to comply with new regulations applicable to installation o Communicate comments and impact assessment to stakeholders o Propose to AFCEC corrective actions to bring plans up-to-date o Plan corrective actions to fix non-compliant situations o Coordinate plan for installation review/signatures o Work with regulators and identify required permit and permit renewals and changes o Comply with permit conditions SAM site evaluations, reporting, etc.

o Complete training of personnel on permit conditions and document (overseas) o Be familiar with Hazardous Material (HM)/HW panel governance process

• Interface with Other Base Activities o Interface with Transient Contractors: HW Managers walk through contractor sites with the contracting officer, Contracting Officer’s Representative (COR), or Quality Assurance (QA) before, during, and after occupancy and ensure that contractors follow the base Hazardous Waste Management Plan (HWMP) or other Operating Instruction (OI) procedures

Attend contract kick-off meetings Coordinate contractor base visit/work Provide input to Contracting Officer’s Technical Representative (COTR) Provide technical review/evaluation of deliverables Identify and work with base-level contracts and AFCEC that will require

COR/COTR support with HW impact and ensure program applicable (i.e., Enterprise Environmental Safety and Occupational Health Management Information System, Department of Transportation (EESOH-MIS, DOT), etc.)

requirement use language is inserted into the appropriate contract vehicles;

ensure contractors whose work generates HW must comply with the installation HW program/requirement identified within their contracts; review contracts and contract performance With Respect To (WRT) HW requirements o Interface with Facility Utilization Board: Participate in quarterly Facility Utilization

Board meetings to advise on base prioritization of Civil Engineer (CE) projects based on environmental concerns o Interface with Planning Groups: Participate and advise within Planning Groups for new missions/bed downs, emergency response, community issues to ensure that environmental and Resource Conservation Recovery Act (RCRA) requirements are addressed o Interface with Construction Activities: Attend construction planning meetings to ensure that any designs or locations are consistent with environmental and RCRA requirements. Also, conduct walk through of construction sites with the contracting officer, COR, or QA to ensure environmental compliance and proper disposal of any generated waste o Interface with HMMP Team: HW Managers must participate in Safety Data Sheet (SDS) reviews and new process authorizations per AFMAN 32-7002, chapter 3.

o Interface with Other Environmental Programs: HW Managers interface with Air, Integrated Solid Waste (ISW), Water, and other environmental programs for report preparation and to serve as Hazardous Waste (HW) subject matter experts when necessary o Interface with Environmental Safety and Occupational Health Council (ESOHC):

HW Managers prepare briefings and tracking metrics for HW specific issues. Also, report on root causes for HW violations.

Support Key Performance Indicator (KPI) metric development as required by EMS or directed by AFCEC

Identify Activity Management Plan (AMP), unique KPI, and Performance Measurement Target (PMT) data requirements

Verify and collect KPI and PMT data has been collected, reviewed, and accurate at ESOHC, input into required dashboards as well as Defense Environmental Program Annual Report to Congress (DEP ARC) reporting database, and input into appropriate AMP

Evaluate system performance; note discrepancies, problems, exceedances, etc.

Take corrective actions to improve performance HW Manager Responsibilities (Establish local procedures and plans)/Post

Award Monitoring Submit required reports to regulatory agencies and HHQ o Interface with Audit Stage Two: Participate in internal audits annually to inspect

HW generators and accumulation points throughout the base for compliance o Ensure workplaces have adequately identified stage one checklists in Management

Internal Control Toolset (MICT) o Identify and locate required document for inspections o Plan, schedule, and participate for auditing Stage two checklists assessment o Input auditing Stage two checklists findings and management action plans into database o Ensure a management action plan and brief to base leadership o Provide data for HW and other environmental program reporting and inventory requirements o When sampling/monitoring indicates changes/discrepancies, take investigative/corrective actions o Advise and consult on RCRA/State/Local/Final Governing Standards (FGS) HW regulations o Arrange for and provide payment for required Resource Conservation and Recovery

Act (RCRA) fees o Implement corrective actions o Ensure findings in database are current and up-to-date

• Establish local procedures and plans o Execute current Fiscal Year (FY) program o Establish local procedures, prepare and maintain the base specific HW management plans in eDASH, and provide technical expertise with regard to waste management requirements o Identify, review, and validate necessary plans; validate scheduled deadlines o Identify and oversee proper programming or project requirements and recordkeeping procedures to meet plan o Review and ensure ESOHC review of Hazardous Waste Management Plans o Identify shortfalls and alert AFCEC/management as needed o Serve as Office of Primary Responsibility (OPR) for the Hazardous Waste

Management Plan, Waste Analysis Plan and contingency plans (OPR implies that the HW Manager is responsible for ensuring plans are written and current) o Check the plan meets requirements (e.g., regulatory and Installation) and identify plan problems and short falls o Submit and/or distribute documents for public comments o Evaluate panel and governance process effectiveness (Evaluate and outline how effective the panel and governance process) o Provide inputs (panel representatives as needed) to others on needs

• Ensure proper centralized management and storage of Hazardous Waste o Establish CE consolidated storage if needed o Ensure compliant management of Treatment, Storage, or Disposal Facilities (TSDFs) where applicable (permitted long term HW storage) o Attend Hazardous Waste Operations and Emergency Response (HAZWOPER) for

TSDF operator training when applicable o Monitor installation activities to evaluate permit compliance o Ensure proper permit maintenance (i.e. ensuring permits are updated and that the storage and management activities meet permit conditions) and notify the AFCEC IST of any updates required or shortfalls o Oversee TSD operation IAW permit conditions o Collect and file HW operating record

• Ensure proper disposal of Hazardous Waste o Establish disposal mechanism with Defense Logistics Agency (DLA).

Submit Memorandum of Services (MOS) to DLA to establish a new contract.

Contract vehicles are renewed every 5 years

Work with DLA to establish Contract Line Item Numbers (CLINs) applicable to the base and project disposal amounts under each CLIN o If DLA is not utilized, work waivers with AFCEC to establish Non-DLA contract vehicles

Perform contract surveillance activities and audits as appropriate (see AFMAN 32-7002, chapter 5) o Establish and oversee other HW related contract vehicles (e.g. lab services, HW management services, recycling, etc.)

Perform contract surveillance activities and audits as appropriate.

o Ensure effective waste characterization program as defined in the Waste Analysis

Plan o Forecast HW types and estimated volumes for Defense Logistics Agency (DLA) contract o Track the on-site disposition of HW o Resolves characterization and HW manifest discrepancies with off-site TSD through

DLA or other contract agent o Justify the use of non-DLA waste disposal contract o Advises generators of HW transportation requirements o Create/review HW turn-in documents and review manifests o Advise generators of HW disposal and turn-in o Review turn-in documents and manifests o Manage on-base HW recycling operations o Track customer reimbursement o Establish, identify, and oversee locations for each Hazardous Waste Accumulation

Site (HWAS) and Initial Accumulation Point (IAP) (coordinate, review, approval) o Identify waste streams for each IAP o Verify during audit evaluations that IAPs are in compliance, waste streams have been properly identified, and records maintained o Implement corrective actions if necessary o Provide guidance and equipment on organization managed HWAS for IAPs management o Establish and oversee locations for each HW accumulation site (HWAS) (90- or 180-day or FGS) sites o Operate at least one central (90- or 180-day or FGS) HWAS o Manage and maintain on-site Quality Assurance Evaluator (QAE) oversight function for HW support contract (obtaining contract and QAE) o Manage the transfer of regulated waste from initial accumulation to central storage o Ensure Wing Commander (or Installation Commander) designates a HW Manifest Signee in writing. This will typically be the HW Manager, but not in all cases

Additionally, HW Manager must ensure that the manifest signee meets the appropriate RCRA/DOT training requirements (see AFMAN 32-7002, chapter

5) and sign manifests, ensure records are maintained

• Ensure proper environmental reporting and record keeping o Maintain HW related records in an approved environmental reporting system and IAW retention times prescribed by the Air Force Records Disposition Schedule (RDS) o Files and preserves manifests and waste analysis IAW RCRA and state records disposition requirements o Identify base-specific recordkeeping update requirements and verify base records are accurate and current o Collect base data, documents and maintain required records (profiles, analytical results, manifest, training, etc.)/files/databases o Adjust recordkeeping process as needed to improve accuracy o Prepare for inspection; notify installation leadership and track inspection results into

EASI

o Escorts regulators on inspection(s) o Review and analyze regulator's report o Respond to regulator’s report o Work final issues with regulator for close-out and coordinate process o Prepares, enters, and submits data for biennial reports, state-specific HW reports, DEP ARC o Be familiar with data call requirements (e.g., annual DEP ARC) o Collect and report essential data to AFCEC on HHQ data calls o Ensure reports and data calls completed o Support installation spill response IAW (Spill Prevention, Control, and

Countermeasures (SPCC)) plan or Facilities Response Plan (FRP) o Provide assistance and guidance to base contracting, CE/installation shops, and other procurers/users of HM/HW o Maintain historical data o Manage onsite HW issues o Validate data is consistent, accurate, and complete

• Budgeting, programming and execution of Hazardous Waste requirements o Oversee proper programming and recordkeeping procedures o Review and ensure ESOHC review of HW Management Plans o Identify IT requirements o Utilize level one eDASH framework to implement EMS o Validate IT system meets needs o Manage Environmental Action Plan(EAPs) within eDASH by anybody in EAP o Access, maintain, and utilize IT tools as directed by the AFCEC (e.g., eDASH, Environmental Actions, Spills, and Inspections(EASI), EESOH-MIS) o Perform gap analysis on AFCEC-directed IT systems o Coordinate and review annual program requirements with AFCEC using AFCEC-directed IT systems o Use AFCEC-directed audit IT tools

Hazardous Waste – “Do Phase” – Element I: Shop/HW Generator Responsibilities the Programming Plan (P-Plan) Revision 1 for Implementation of Enterprise-Wide Civil Engineer Transformation (PAD 12-03), Volume 2, this narrative describes the ongoing responsibilities of the shop and/or hazardous waste (HW) generator.

Shops and HW generators have the following ongoing responsibilities throughout the HW Management Program:

• If HW is generated, shop/HW generators establish and oversee HW initial accumulation point (IAP) signage, equipment, supplies (ensure obtaining supplies such as HW containers is in conformance with installation specified standards; HW labels may be centrally issued from the Environmental Office), and segregation

• Conduct self-assessments (as a part of Stage One audit assessment requirements), maintain self-assessment records, and comply with 40 Code of Federal Regulations (CFR 262 subpart C), Generator Requirements

• Plan and participate in auditing assessments

• Ensure workplaces have adequately identified Stage I checklist in Management Internal Control

Toolset (MICT)

• Implement corrective actions

• Ensure findings in database are current and up-to-date

• Ensure management action plan for each finding

• Ensure funding is available for HW container/initial accumulation point (IAP) supplies/equipment

(unit funded)

• Manage initial accumulation points and hazardous waste accumulation site (HWAS), where applicable, in accordance with the installation HW Management Plan (HWMP) and all applicable policies, regulations, and laws

• Ensure that all waste streams are properly characterized (i.e., to determine whether or not they are hazardous wastes) and appropriate documentation is maintained. Ensure that all new and existing waste streams and/or process changes have been coordinated with the base environmental office. Ensure that any waste streams generated are determined to be either hazardous or non-hazardous at the point of generation of the waste. Coordinate process and waste changes with the bioenvironmental engineering office to determine any occupational or environmental health risk

• Document generator knowledge

• Notify the environmental and bioenvironmental engineering offices of all administrative changes in HW activities including, but not limited to, the location or relocation of initial accumulation points and HWAS, and names of accumulation point/site managers and alternates

• Prepare for inspection

• Review and analyze regulator’s report

• Identify personnel needing training and identify training requirements and effectiveness

• Schedule and verify required training is completed and effective

• Provide training as necessary when AFCEC availability impacts ability for timely training

• Attend Air Force Institute of Technology (AFIT) training as required

• Maintain training records/documentation

• Ensure and maintain that appropriate employees are trained and coordinate all training and record/documents with CE (supervisory role)

• Ensure that each generating activity unit organization designates an employee and an alternate to serve as a focal point for the organization’s waste management activities

• Follow the installation HWMP

Hazardous Waste – “Do Phase” – Element I: DLA Responsibilities the Programming Plan (P-Plan) Revision 1 for Implementation of Enterprise-Wide Civil Engineer Transformation (PAD 12-03), Volume 2, this narrative describes the ongoing responsibilities of the Defense Logistics Agency (DLA).

DLA has 12 main, ongoing responsibilities throughout the Hazardous Waste Management Plan (HWMP):

• Provide hazardous waste (HW) disposal contracting and oversight services to installations

• Provide completed uniform HW manifests and Environmental Protection Agency (EPA) land disposal restriction certifications based on information provided by the waste generators

• Provide a copy to Civil Engineer (CE) of all HW manifests and Land Disposal Restriction

(LDR) certifications at the time of initial removal of the HW from the installation; and provide the original of the “closed” HW manifests and a copy of the Polychlorinated biphenyl (PCB) Certificates of Destruction once received from the Treatment, Storage, and Disposal Facility

(TSDF)

• In addition to the base, Defense Logistics Agency (DLA) keeps records of all Hazardous Waste Profile Sheets (HWPS) and associated reference numbers, and maintains copies of manifests

• Perform pre and post award monitoring of contractor performance

• Dispose of excess/surplus HM property in place through reutilization, transfer, donation, sale

(RTDS), and contract disposal, if necessary. All hazardous and universal waste (HW/UW)shall be handled through DLA contract disposal

• Ensure compliance, from employees and contractors, with all applicable Federal, State and base environmental, transportation, and safety laws and regulations

• Ensure that authorized customers/contractors comply with base security policies for gaining access to and for conducting business on the base

• For HW/Universal Waste (UW), DLA intends to process the property for removal within 60 days of accountable receipt by DLA unless the generator requests an expedited removal. For Hazardous Material (HM), DLA intends to process the property for removal within 180 days of accountable receipt unless the generator agrees to a longer time frame

• Provide certificate of destruction for Hazardous Waste and PCB certificates of destruction

• If requested, provide Certificate of Recycling upon recycling of HW

• General Contracting and Communication (GENCOM) interface with Enterprise Environmental

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

• Any user can identify EESOH-MIS requirements

• Identify software requirements or changes to existing software

• Participate in the EESOH-MIS HW Functional Working Group (FWG), as required

Hazardous Waste – “Do Phase” – Element I: IAP Responsibilities the Programming Plan (P-Plan) Revision 1 for Implementation of Enterprise-Wide Civil Engineer Transformation (PAD 12-03), Volume 2, this narrative describes the ongoing responsibilities of the Initial Accumulation Point (IAP).

IAPs have both regulatory and AF responsibilities that are mandatory to maintain a successful Hazardous Waste Management Program (HWMP).

IAP Regulatory Responsibilities

• Mark waste containers with words “Hazardous Waste” or content of container

• Keep container lids closed when not adding or removing waste

• Maintain containers at or near point of generation

• Ensure that the maximum of 55 gallons of hazardous waste or one quart of acutely hazardous waste is not exceeded at the IAP

• Mark the date on the containers or the container labels with the date that the “limit” is exceeded. In the case of a 55 gallon drum, the date is when the container is considered full

• Move containers to the Hazardous Waste Accumulation Site (HWAS) within three days of the date that the “limit” quantity was exceeded, or as required by state or local procedures

• Ensure all markings/labels on containers are visible while being stored at the IAP

• Ensure compatibility of all wastes at the IAP

• Use only “approved” containers capable of being loaded and transported for collecting and moving hazardous waste (HW)

• Obtain and maintain a spill response kit at the IAP

• Ensure IAP managers have received initial and refresher training

• Ensure containers are used and managed in accordance with 40 Code of Federal Regulation

(CFR) 265 Subpart I, “Use and Management of Containers”

IAP AF Responsibilities

• Responsible for the management of the IAP and waste streams generated

• Ensure HW accumulation complies with Federal, State, and local HW management requirements

• Coordinate each HW accumulation location with the installation HWMP, Ground Safety, Fire

Protection and Bioenvironmental Engineering (BE)

• Provide and maintain proper equipment and safe locations for IAPs

• Ensure a sign is posted at the IAP that designates the location as an IAP and lists the name and phone number of the IAP Manager and their alternate

• Ensure…