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Text version
Template Version June 2020
U. S. AIR FORCE
HAZARDOUS WASTE MANAGEMENT PLAN
SPACE LAUNCH DELTA 45
12/1/2021
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:
Annual Review
First Edition 001 New Format 1/23/2017 002 Annual Review/Format
Change 7/15/2019
003 Annual Review 6/2/2020 004 Annual Review 9/3/2021
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 12/3/2020 45 MSG/CD Annual Review – administrative changes only 12/1/2021 SLD 45/TD Annual Review (AFCEC template change)
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
Summary
The purpose of the Space Launch Delta 45 (SLD 45) HWMP is to provide guidance to ensure the proper handling and disposal of all hazardous waste in accordance with 40 Code of Federal Regulations (CFR) 260-279 and Florida Administrative Code (FAC) 62-730. The SLD 45 Hazardous Waste Management Plan is intended to be utilized by all relevant personnel and supervisors that produce or could potentially produce waste.
To ensure uniformity and continuity on environmental issues, 45 CES/CEIE Environmental Office is the single point of contact with federal, state and local environmental regulatory agencies. Each organization generating hazardous waste is responsible to identify, characterize, segregate, containerize, label, mark and minimize their wastes in accordance with federal and state regulations. Each organization must retain all records of their hazardous waste activities.
The Patrick Fence to Fence Contractor (Patrick F2F), as directed by 45 CES/CEIE Environmental Office, will provide hazardous waste management and technical support for CCSFS and PSFB, including tenants and SLD 45 mainland sites.
Downrange outside continental United States (OCONUS) sites will receive hazardous waste management and technical support from the Range Operations Support (ROS) Contractor. Hazardous wastes generated at United States (US) installations located overseas are subject to notification requirements in 40 CFR 264.12.
Federal and state hazardous waste regulations and AFMAN 32-7002 require personnel managing or handling hazardous waste to be trained no later than 6 months after assignment to hazardous waste duties and annually thereafter.
Scope
The collection, management, transportation and disposition of hazardous wastes are defined and strictly regulated in the Resource Conservation and Recovery Act of 1976 (RCRA) as amended and in the corresponding regulations in 40 CFR, Parts 260 through 280 and FAC Chapter 62-730. The collection, management, transportation and disposition of waste petroleum products and other waste are also regulated by various federal and state regulations. Civil and criminal penalties are associated with the violation of these regulations.
This plan applies to all SLD 45 personnel, contractor and tenant organizations that generate waste on CCSFS, PSFB, Jonathan Dickinson Missile Tracking Annex, Malabar Transmitter Annex and Ascension Auxiliary Air Field. Non-Department of Defense (DOD) tenants (e.g., National Aeronautics and Space Administration (NASA), Department of State and US Coast Guard) are responsible for environmental compliance, waste management and disposal in accordance with applicable regulations under their own EPA Identification Number. Commercial space companies that are required to obtain their own EPA Identification Number for their commercially generated waste may also be required to adhere to this plan.
US Space Force (USSF) hazardous waste operations on PSFB are identified by a unique EPA ID number.
PSFB stores hazardous waste in excess of 90 days under a permit issued by the FDEP.
USSF hazardous waste operations on CCSFS are identified by a unique EPA ID number. CCSFS stores hazardous waste in excess of 90 days and operates a thermal treatment unit under a permit issued by
FDEP.
USAF hazardous waste operations on Malabar Transmitter Annex (MTA) and Jonathan Dickinson Missile Tracking Annex (JDMTA) are identified by a unique EPA ID number. Both MTA and JDMTA may operate as Very Small Quantity Generators as long as the requirements of 40 CFR 262.14 are met.
USAF hazardous waste operations on Ascension Auxiliary Air Field (AAAF) are identified by a unique EPA ID number. Wastes generated from operations at this OCONUS location are retrograded back to continental United States (CONUS) for treatment or disposal.
Overview
To ensure uniformity and continuity on environmental issues, 45 CES/CEIE Environmental Office is the single point of contact with state, local and federal environmental regulatory agencies. Commercial space entities operating under a company specific EPA ID number are authorized to contact the state, local and federal environmental agencies directly and notify the Space Force (SF).
Each organization generating hazardous waste is responsible to identify, characterize, segregate, containerize, label, mark and minimize their wastes in accordance with state and federal regulations.
Each organization must also retain all records of their waste activities. SF generated waste will be profiled using the Process Waste Questionnaire (PWQ) Technical Response Package (TRP) process. This hazardous waste characterization mechanism will be performed by Patrick F2F.
Organizations utilizing contracted services and contractors utilizing sub-contractors are responsible for ensuring their contractors comply with all federal, state, local and AF environmental regulations as well as with this plan. For the purpose of contract operations the word "should" means "shall" for all contract operations pertaining to this plan.
Hazardous waste/controlled waste generated from contracted cleanup or remediation projects or construction or demolition and renovation contracts does not have to be disposed through the Defense Logistics Agency (DLA). If a contract is written where the contractor is responsible for the proper disposal of hazardous waste/controlled waste, the waste manifest will use the Air Force EPA ID number and the 45 CES/CEIE Hazardous Waste Program Manager will sign the manifest.
Commercial space entities operating under an executed real property agreement with the AF are required to obtain a company specific EPA ID number. These commercial contractors must manage and dispose of their hazardous waste under that number.
Under RCRA, as the landowner, the Installation Commander retains the authority to request that any tenant organization or contractor generating regulated hazardous wastes obtain their own independent EPA Identification Number.
Environmental management and technical support for CCSFS, including tenants and SLD 45 mainland sites, will be provided by the Patrick F2F as directed by 45 CES/CEIE Environmental Office. The Patrick F2F will maintain a hazardous waste site listing of all generators at PSFB and CCSFS which can be accessed by CEIE and will be supplied to emergency personnel as necessary. A hard copy of all site openings and closings will also be maintained by the Patrick F2F.
45 CES/CEIE Environmental Office will provide downrange OCONUS sites with environmental management and technical support to Range Operations Support (ROS). 45 CES/CEIE Hazardous Waste Program Manager will provide RCRA Reporting Notice to Air Force Hazardous Waste SME for any OCONUS waste entering a CONUS port or Air Force installation. Specific guidance for OCONUS downrange sites is provided in Appendix J.
Services for waste sampling, pickup, PWQ, TRP, packaging assistance and disposal of petroleum products, hazardous and controlled wastes are currently the responsibility of SLD 45 and the Patrick F2F Contractor, unless otherwise specifically identified.
Federal and State hazardous waste regulations and AFMAN 32-7002 require personnel managing or handling hazardous waste to be trained no later than 6 months after assignment to hazardous waste duties and annually thereafter. A new hazardous waste operator must work under the direction of a trained operator until hazardous waste training is received. Current guidance from FDEP defines annually as once per calendar year. In guidance from EPA, Faxback 14286, the Agency states “While it may be infeasible for companies with many employees to train each employee exactly one year after the last training, the Agency does expect companies to attempt to provide training so that personnel are trained every year.”
Personnel must maintain and at the time of inspection by SF, EPA or FDEP be able to provide documentation that they have received the required hazardous waste training as well as a job description as described in 40 CFR 262.17. Training may be obtained by contractor "In-House", commercial or Government sources.
Lead based paint removal and disposal shall be conducted in accordance with Federal, State and local regulations. All paint waste generated from paint removal operations must be containerized, sampled and analyzed to determine whether the waste meets the definition of hazardous waste.
Polychlorinated Biphenyl (PCB) items will be managed in accordance with 40 CFR 761 and Appendix M of this plan.
Asbestos management, removal and disposal shall be conducted in accordance with Federal, State, local regulations and SLD 45 Asbestos Management Plan. Coordination with 45 CES/CEIE Environmental Office and Bioenvironmental Engineering is required prior to any asbestos operations to include disturbance, removal, or disposal.
Per 40 CFR 264.12 the USAF must notify both FDEP and EPA in writing 60 days prior to receipt of hazardous waste from a foreign source. For the SF to supply hazardous waste support to a foreign vessel, the Patrick F2F office must be notified prior to the anticipated receipt of waste with the following information:
• Nature of the waste (i.e., EPA waste codes)
• Reason/requirement for off-loading the waste.
2.0 INSTALLATION PROFILE
Installation Profile
Scope of Plan This plan applies to all SLD 45 personnel, contractor and tenant organizations that generate waste on CCSFS, PSFB, the Florida Annexes and all downrange licensed or operated sites. Non-DOD tenants (i.e., NASA, Department of State and US Coast Guard) are responsible for environmental compliance, waste management and disposal in accordance with applicable regulations under their own EPA Identification Number. Commercial space entities that are required to obtain their own EPA Identification Number for their commercially generated waste may also be required to adhere to this plan
OPR (Civil Engineer or other designated office)
45 CES/CEIE 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 Brian Ellis: 321-494-9270 Alternate HW Program Manager Heather Goslin: 321-494-9268 Emergency contacts 45 CES/CEIE 24/7 Spill Phone: 321-298-7022 Waste registration numbers Waste registration numbers are available as necessary from the Hazardous Waste Program Manager HW generator status Large Quantity Generator Universal waste handler status Small Quantity Generator Permitted HW operations Treatment, Storage and Disposal Facilities and EOD Range Federal regulatory references 40 CFR 260-280 State and local regulatory agencies Florida Department of Environmental Protection State and local regulatory references FAC 62-730 DLA-DS area office and/or approved HW disposal contractors
Defense Logistics Agency (DLA)
HW accumulation sites Contact Patrick Fence to Fence (Patrick F2F) Contractor HW accumulation time limits <90 Days HW generator reporting frequency Biennial
3.0 ENVIRONMENTAL MANAGEMENT SYSTEM
The AF adheres to the EMS framework and its Plan, Do, Check, Act cycle for ensuring mission success.
Executive Order (EO) 13834, Efficient Federal Operations, U.S. Department of Defense Instruction (DoDI) 4715.17, Environmental Management Systems, AFI 32-7001, Environmental Management, and International Organization for Standardization (ISO) 14001, Environmental management systems - Requirements with guidance for use, provide guidance on how environmental programs should be established, implemented, and maintained to operate under the EMS framework.
The HW management program employs EMS-based processes to achieve compliance with all legal obligations and current policy drivers, effectively manage associated risks, and instill a culture of continuous improvement. The HWMP serves as an administrative operational control that defines compliance-related activities and processes.
Environmental Action Plans (EAPs) are developed and maintained as part of the overall EMS on eDASH.
EAPs are tools that translate environmental requirements and targets into actionable plans for the HWPM and responsible personnel. HW requirements should be incorporated in installation EAPs to record monitoring and conformance for inspections and audits.
4.0 ROLES AND RESPONSIBILITIES
The major roles/organizations involved in supporting the HW program include:
• Wing/Installation Commander
• ESOHC
• EMS CFT
• HW Program Manager/Alternate(s)
• Shop/HW Generator Personnel
• 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 Safety and Occupational Health Council
The Environmental, Safety and Occupational Health Council (ESOHC) is required by AFI 90-801. The ESOHC meets biannually to discuss SLD 45 environmental issues. The ESOHC membership is defined in AFI 90-801. This committee has the function of communicating environmental policy and environmental actions to Wing organizations. The ESOHC is responsible for SLD 45 compliance with all federal, state and local environmental regulations. If an ESOHC member is unable to attend, the role should be delegated to someone who is aware of all major actions of that organization.
The ESOHC members must regularly attend SLD 45 ESOHC meetings. With only two one-hour meetings a year, 100 percent attendance of the ESOHC meetings is expected. The ESOHC will:
• Ensure that all activities in the organization implement procedures to comply with State and Federal hazardous waste laws and SLD 45 Environmental Policies and Plans.
• Provide organizational data to the 45 CES/CEIE Environmental Office for environmental permit applications, compliance reports and corrective response resulting from spill incident, regulatory inspections and enforcement actions.
• Ensure that all organization personnel are currently trained per Federal and State regulations and provide supplemental training and supervision to new personnel who handle or manage hazardous materials or wastes.
45 CES/CEIE Environmental Office
• The office responsible for this plan.
• Provides technical assistance to operational activities and oversight of Patrick F2F, ROS, CCSFS and PSFB contracts.
• Submits petroleum and hazardous waste reports to regulatory agencies as required by permits, State and Federal regulations.
• Oversees the SF hazardous waste training programs.
Fire Emergency Services, 45 CES/CEF (PSFB)
• Ensures fire protection equipment and base wide fire extinguishers are in working order.
• Responds to hazardous waste or materials spill/release incidents upon notification.
Fire Emergency Services, 45 CES/FEMS (CCSFS)
• Ensures fire protection equipment and base wide fire extinguishers are in working order.
• Responds to hazardous waste or materials spill/release incidents upon notification.
Bioenvironmental Engineering, 45 AMDS/SGPB
• For limited special circumstances and upon request, collects, prepares and coordinates sampling for analysis to an approved laboratory.
• As requested and during routine surveys, identifies special personal protective equipment requirements for AF personnel.
Cape Launch Operations and Infrastructure Support (CLOIS)
• Responds to all spills (hazardous materials, oil, fuel, etc.) at all SLD 45 mainland sites. At CCSFS, response will include immediate containment of spill and any other actions necessary to avoid hazards to human health or the environment. Provides cleanup and containerization of any spilled material at all SLD 45 mainland locations.
Defense Logistics Agency (DLA)
• Markets excess and/or recyclable materials in accordance with DLA procedures and Federal, State and local regulations. Disposes of hazardous items that cannot be marketed.
• Upon request, obtains off-site disposal contracts in accordance with applicable regulations for hazardous and non-hazardous wastes and PCB items for all SLD 45 sites.
• Contracts for recycling/treatment/disposal services. Responsible for ensuring hazardous waste disposal services comply with all applicable regulations governing the handling, transportation, storage, treatment and disposal/reclamation of the waste.
• Arranges for off-site treatment, storage and disposal of waste streams to include completion and submission of all required paperwork. Arranges for transportation to the off-site facility. Ensures off-site facility is permitted to accept wastes as generated. Maintains copies of required records including disposal contracts, manifest, land disposal restriction (LDR) certifications and certifications of disposal. Provides the Patrick F2F and 45 CES/CEIE Environmental Office with originals of completed manifests and LDR certifications within 45 days from date of off-site shipment. Audits off-site disposal facilities for regulatory and permit compliance annually.
HazMart
• HazMart is responsible for management and operation of the AF approved hazardous materials tracking system and of the hazardous materials storage and distribution facility.
• HazMart personnel are responsible for determining current conditions and identifying further uses of hazardous materials returned by initial user. Hazardous materials determined not to be viable for further use are managed in accordance with this plan as hazardous or controlled waste.
Materials Recycling Facility (MRF)
• The MRF is responsible for recycling services through innovation, technology and other means, for both PSFB and CCSFS. The MRF recycles all paper (white, colored, newspaper, light cardboard), cardboard, some plastic bottles, used oil and oil filters, aluminum & steel cans, scrap metal, magazines, notebooks (binders), brown paper and plastic bags, CD disks, floppy disks, jewel cases, binder spines, toner and laser cartridges and other materials as determined economically feasible. For more information on recycling services call (321) 494-6848.
Patrick Fence to Fence (Patrick F2F)
• Implements a Hazardous Waste Management Program for the SLD 45 as directed by 45 CES/CEIE Environmental Office. This program includes coordinating with other organizations/contractors to ensure proper identification, storage and removal of all hazardous wastes. Provides guidance and technical support for environmental questions, concerns and problems on CCSFS, PSFB and other AF mainland sites. Generates, collects and consolidates technical data and prepares, revises, updates and implements hazardous waste management plans and procedures. Performs the requirements of the Commander’s Compliance Inspection Program (CCIP) self-inspection checklists.
• On a quarterly basis, reviews and inspects all hazardous waste accumulation sites on CCSFS, PSFB and mainland annexes including tenants and contractors, to ascertain compliance with State, Federal and AF hazardous waste regulations and this plan. Provides written notification of inspection deficiencies to the 45 CES/CEIE Environmental Office of accumulation sites to ensure deficiencies are corrected in a timely manner; re-inspects sites to verify deficiencies have been corrected.
• Operates and maintains compliance at AF permitted hazardous waste storage facilities.
• Maintains listing of all hazardous waste <90-day and satellite accumulation areas and information concerning waste streams generated. Provides site approval for all new hazardous waste accumulation sites and inspections for site closures.
• Responds to all spills (hazardous materials, oil, fuel, etc.) at CCSFS for the purpose of information gathering and to provide technical assistance if requested. Provides all information gathered to 45 CES/CEIE Environmental Office.
• Provides services for waste determinations, PWQ TRPs, hazardous waste sampling, transportation, packaging assistance and disposal of petroleum products, hazardous and controlled wastes.
• Provides written TRPs to the requester for all PWQs. TRPs include technical assistance on matters of containerization, labeling, marking, handling and parameters for chemical analyses.
• Provides proper containerization for purposes of both on base waste transportation and shipment to off-site disposal facilities.
• Establishes and supports transportation operations for the expeditious removal of waste from operational areas as requested. Transports hazardous waste from satellite accumulation sites to <90-day accumulation sites and/or on-site permitted storage facilities within regulatory time limits. Coordinates transportation operations with requestor.
• Provides chemical analyses of waste products for disposition purposes in a timely manner for all SLD 45 generators as requested.
Range Operations Support Contractor (ROS)
• Implements a Hazardous Waste Management Program for the ROS operated facilities.
Generates, collects and consolidates technical data and prepares, revises, updates and implements hazardous waste management procedures. Implementation shall include review of facility adequacy, forecast of yearly generation, provides training for all personnel managing hazardous waste, quarterly site inspections and coordination with other agencies/contractors to ensure proper identification, storage and removal of all hazardous wastes. Ensures deficiencies found during quarterly inspections are corrected in a timely manner and verifies deficiencies have been corrected. Provides a written report to 45 CES/CEIE Environmental Office of all uncorrected deficiencies. Manages wastes in accordance with Appendix J to this plan at downrange sites.
• Reviews and inspects in accordance with the Commander’s Compliance Inspection Plan (CCIP) at all ROS operated facilities.
• Implements and supports this plan. Reviews and revises Appendix J annually and provides revisions to 45 CES/CEIE Environmental Office. Responds to all spills (hazardous materials, oil, fuel, etc.) at ROS downrange facilities. Response will include immediate containment of spill and any other actions necessary to avoid hazards to human health or the environment, as well as subsequent cleanup, containerization, management and disposition of any spilled material.
Immediately notifies 45 CES/CEIE Environmental Office of the release.
Facility Operating Organizations
• Each organization generating hazardous waste is responsible to identify, minimize, package, label, mark, prepare the internal manifest and ensure record keeping is complete and up to date in accordance with applicable Federal and State regulations and this plan regarding their wastes.
The generator of hazardous waste retains responsibility until ultimate disposition of that waste. It is the generators' responsibility to request and ensure that sampling and transportation are performed in a timely manner.
• Problems complying with this plan or the State and Federal hazardous waste regulations should be addressed through organizational command channels to 45 CES/CEIE Environmental Office as soon as possible. DO NOT DELAY IN IDENTIFYING A PROBLEM.
• Federal and State hazardous waste regulations and AFMAN 32-7002 require personnel managing or handling hazardous waste to be trained no later than 6 months after assignment to hazardous waste duties and annually thereafter. A new hazardous waste operator must work under the direction of a trained operator until hazardous waste training is received. Personnel must maintain and be able to provide at the time of inspection by AF, EPA or FDEP personnel documentation that they have received the required hazardous waste training as well as a job description as described in 40 CFR 262.17. Training may be obtained from contractor "In- House", commercial or Government sources.
• It is the generator’s responsibility to ensure that accumulation time limits are not exceeded at <90-day accumulation site(s). If problems arise or a time extension is required, telephone the Patrick F2F at 853-6985 or 494-9270 for CCSFS and PSFB before the 75th day.
Public Affairs, 45 SW/PA
• Acts as focal point for inquiries from the news media and concerned citizens regarding hazardous waste or petroleum products incidents or accidents that may occur.
TABLE 1: Emergency Phone Numbers PSFB and CCSFS On-Base Organizations
PSFB Organization Duty Hours After Duty Hours Fire Department, EMERGENCY 911 911 Hazardous Materials Response Team 911 911 Hospital, EMERGENCY 911 911 Law Enforcement, EMERGENCY 911 911 Law Enforcement Desk 494-2008 494-2008 SLD 45 Command Post 494-7001 494-7001 45 CES/CEIE Environmental office 494-9270 321-298-7022 45 CES/CEX Emergency Management Flight 494-4224 494-7001 45 CES/CED Explosives Ordnance Disposal (CCSFS) 853-8888 494-7001 45 OMRS/SGXB (Bioenvironmental Engineering) 494-5435 321-482-3811 45 WS Weather Operations 853-8484 853-8484 SLD 45 Judge Advocate 494-7357 Fire Dept. Hazardous Material Response Team 853-0911 853-0911 Security Forces Base Defense Operations Center 853-2121 853-5211 Cape Support 853-5211 853-5211 Detachment 1, 45 MSG/CC 853-3900 853-5211 Patrick Fence to Fence (F2F) 853-6985 853-5211 Emergency Preparedness 853-6861 853-5211 NEMCON Industrial Hygiene 867-2400 867-2400 Post-emergency Spill Cleanup Team 853-5211 853-5211 NEMCON Environmental Compliance and Public Health 867-7138 867-2400 CCSFS Explosive Ordnance Disposal 853-8888 853-5211 SLD 45 Occupational Safety 494-7233 494-7001 Naval Ordinance Test Unit Duty Office 853-1240 853-1240 Harbor Control/Dock master 853-1245 853-1245
TABLE 2: Emergency Phone Numbers Off-Base Organizations
Federal
Organization Phone Center for Disease Control 800-232-4636
CHEMTREC 800-424-9300
CHLOREP, Chlorine Emergency 800-424-9300 Drug Information Center 213-226-7741 EPA Emergency Planning Hotline 800-424-9346 EPA RCRA Superfund Hazardous Waste/Emergency Response 800-424-9346 EPA Region IV Emergency Response 800-282-9378 National Response Center (NRC) 800-424-8802 Poison Control Center 800-222-1222 Toxic Substances Control Act (TSCA) Hotline 202-554-1404 US Department of Transportation (DOT) Hotline 202-366-4488
Merritt Island National Wildlife Refuge 321-861-0667
State
Organization Phone Central District Orlando, Department of Environmental Protection 407-897-4100 Headquarters Tallahassee, Department of Environmental Protection 850-245-2010 Florida Fish and Wildlife Commission (Law Enforcement) 352-732-1225
County
Organization Phone Sheriff, EMERGENCY 911 Fire Department, EMERGENCY 911 Brevard County Emergency Management 321-637-6670 Brevard County Sheriff 321-264-5201 Florida Highway Patrol 321-690-3900 American Red Cross 321-890-1002
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
• AFMAN 32-7002, requires all personnel managing or handling hazardous waste must receive hazardous waste training annually. All personnel who are required by 40 CFR 262.17 and/or the FAC to receive hazardous waste training shall be trained no later than 6 months after assignment to hazardous waste duties. A new hazardous waste operator must work under the direction of a trained operator until hazardous waste training is received. Personnel receiving training under these regulations must maintain and be able to provide the required documentation identified in 40 CFR 262.17(a)(7)(iv) for inspection purposes. Training may be obtained by contractor "In- House", commercial or government sources. Patrick F2F will distribute training slides for generators to review annually to meet training requirements.
• All 90-day site accumulation generators must receive DOT-required training.
• Personnel who manage the permitted hazardous waste storage facilities or who are authorized to sign Uniform Hazardous Waste Manifests must complete DOT training in accordance with 49 CFR 172.704 once every 2 years. Contact the Environmental Office 494-9270 to set up DOT required training. Hazardous Waste Operator training in accordance with OSHA (29 CFR 1910.120) is also required for permitted storage and treatment facility personnel.
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 primary exporters of HW)
40 CFR 262.83(g) 3 years from the date the HW was accepted by the initial transporter
40 CFR
262.83(i)(1)(ii)
Employee training records (including appointment letters for key HW personnel)
40 CFR
262.16(b)(9)(iii)
40 CFR
262.17(a)(7)(iv) 40 CFR 264.16(d) 40 CFR 265.16(d)
For interim and permitted operations- current personnel: until closure of the site; Former personnel: 3 years from date the individual last worked there. For all other LQGs and SQGs, the best management practice is to retain for 3 years to demonstrate compliance
40 CFR
262.17(a)(7)(iv) 40 CFR 264.16(e) 40 CFR 265.16(e)
*Permitted Treatment, Storage, and Disposal Facilities (TSDF) comply with recordkeeping requirements established in their HW permit.
**Retention Time may be extended during the course of any unresolved enforcement action or as requested by the EPA. The AF, through the Air Force Records Information Management System (AFRIMS), requires that HW-related reports, documents, studies, HW manifests, and disposal records (including contracts) are destroyed 50 years from the date of the record. Note that the records required by law or external regulation, should be readily available on-site. Records required by AF Record Retention requirements can be archived.
Reporting
The HW Program Manager, and other designated personnel, generate needed reports from the Enterprise Environmental, Safety, and Occupational Health - Management Information System (EESOH-MIS).
Enforcement actions, spills, and inspections are reported via the Enforcement Actions, Spills, and Inspections Environmental Reporting (EASIER) database.
Installation Supplement – Recordkeeping and Reporting
SLD 45 Environmental Office uses the Hazardous Waste Site Master database for all quarterly inspections conducted by Patrick F2F Support Contractor.
Hazardous Waste Shipping Log database is kept for all off-site shipments from CCSFS.
EASIER database is maintained for all CCSFS reported spills.
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
SLD 45 personnel manually record all items brought into the TSDF and 90-day sites per RCRA permit.
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
Process Waste Questionnaires and Technical Response Packages
• All waste generating organizations at PSFB and CCSFS and mainland annex shall provide a PWQ for each waste stream for appropriate characterization prior to waste generation (Figure 1).
The generator should provide as much information on the PWQ as possible about the waste stream, such as waste generating processes, chemical analysis and/or safety data sheets (SDS) for the materials used to generate the waste. Organizations that generate characteristic waste must identify any UHCs that may be present in the waste stream. A PWQ addendum may be issued to the waste generating organization for disclosure of the UHCs. Once the Environmental Coordinator has determined the PWQ to be complete, it must be submitted to the Patrick F2F Contractor at 45CES.ESC.HazWasteSupport@us.af.mil. NOTE: If the PWQ does not contain complete and detailed information about the waste and the waste generation process, it may be returned to the waste generating organization for additional information. This slows down the process of generating a TRP.
• A Process Waste Code and handling information will be provided in writing through a TRP prepared and provided by the Patrick F2F. The TRP provides a waste determination as well as information pertaining to required labels, markings, containers, sampling, and disposition instructions. The information given on a TRP is specific and changes to this information by the generator are not authorized. If no TRP has been received for the PWQ within seven working days, contact the Patrick F2F or your environmental coordinator to determine the status of the evaluation.
• Any questions or concerns about a particular waste stream shall be answered by the generator or the generator's Environmental Coordinator. Disagreements between the Patrick F2F and the generator or the generator's Environmental Coordinator on a particular waste stream shall be resolved by the 45 CES/CEIE Environmental Office.
• Only after the TRP has been received by the generator or the generator's Environmental Coordinator can a waste be processed for disposition through the waste support request process.
• For any unknown waste that is discovered or if a generator is unable to predict waste properties prior to generation, the waste containers should be labeled with a "Hazardous Waste Determination in Progress (HWDIP)" label and managed in an accumulation site. The label should be filled out completely to reflect the date on which the accumulation started, contents, a point of contact, phone number and organization responsible for managing the waste. The organization responsible for managing the waste must track on the label and in a log the date the analysis request was submitted, the date the sample was taken, the date the analysis results were received and the date the PWQ was submitted. The entire process should not take longer than 90 days. For new or unknown waste streams the accumulation start date will be defined as the date upon which the technical response package (TRP) is issued. For existing waste streams that are mailto:45CES.ESC.HazWasteSupport@us.af.mil sampled to identify which TRP is applicable (usually hazardous or non-hazardous), the accumulation start date will be defined as the date of the chemical analysis lab report.
• No wastes or rinsates may be discharged to the sanitary sewer system without prior authorization provided by CLOIS for CCSFS and 45 CES/CEIE for PSFB through the PWQ/TRP system.
• At no time shall wastes be discharged to grade or to waters of the State of Florida without authorization from the State of Florida through the 45 CES/CEIE Environmental Office.
Sampling and Analysis Support
• It is the generator's responsibility to determine whether the generated waste meets the waste description on the original PWQ for that waste stream. If the generator is unsure whether the generated waste meets the PWQ waste description, sampling and analysis shall be conducted for verification. The sampling and analysis section of the TRP provides the recommended analysis parameters.
• Support for sampling and analysis is requested by submitting a Sampling and Analysis Authorization Form (see Figure 2) to Patrick F2F via email to 45CES.ESC.HazWasteSupport@us.af.mil or by calling 321-423-8391. The Sampling and Analysis Authorization Form requires the requester (generator) to identify necessary information such as: on-site contact, number of samples to be taken, sampling parameters, waste location, what type of container the waste is in, date when analysis should be completed, etc. If you call Patrick F2F to make sampling and analysis arrangements, they will require the same information.
• Patrick F2F Sampling will provide a tracking number for the sampling operation. The generator or Environmental Coordinator shall retain this number for future reference
FIGURE 1: Process Waste Questionnaire
FIGURE 1: Process Waste Questionnaire (Continued)
FIGURE 2: Waste Characterization Sampling Request
FIGURE 2: Waste Characterization Sampling Request (Continued)
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
• Prior to waste generation, each generator will complete a Process Waste Questionnaire (PWQ) and submit it to the Patrick F2F for characterization and waste disposal determination. Patrick F2F will provide each generator with a TRP. The TRP identifies the proper container to be used for collection of each waste.
• It is the responsibility of the generator of a hazardous or controlled waste to ensure that the waste is placed in a US Department of Transportation (DOT) approved shipping containers, marked, labeled, and stored in compliance with the requirements of 40 CFR 262.30-32, 49 CFR 172.304, 173, 178 and 179. This requirement applies when accumulation of waste begins.
• Generators should maintain an appropriate number of approved containers to adequately meet their waste generation needs. Both Patrick F2F and 45 CES/CEIE maintain stock of DOT containers that can be issued to a generator in an emergency on a reimbursable basis.
Refer to Appendix F – Waste Container Management Plan for detailed information on container management.
7.4. Labeling and Marking
Containers used for the accumulation and transportation of HW are properly labeled IAW applicable laws and regulations.
Each container is properly marked and labeled from an IAP to HWAS to disposal/turn-in. The waste-generating activity ensures that the label on each waste container is clearly visible for inspection.
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