Attachment 10 - Hohenfels HWMP.pdf

UNITED STATES ARMY

GARRISON (USAG) BAVARIA,

HOHENFELS

INTEGRATED

HAZARDOUS WASTE MANAGEMENT PLAN (HWMP)

Last updated

30 January 2021 ii

APPROVALS

This Hazardous Waste Management Plan (HWMP) addresses management requirements specific to United States Army Garrison (USAG) Hohenfels current and planned waste generation and disposal activities.

This HWMP must be reviewed and updated at least once every five years.

Prepared Sep 2008 by:

Jochen Dörr, Contractor Cardno TEC GmbH Carl-Benz-Strasse 5

68723 Schwetzingen

Updated by:

ORIGINAL SIGNED

January 2021

Ana Gonzalez, Contractor WOOD E&I GmbH

Date

Approved by:

Silke Bornemann Garrison Hazardous Waste Management Program Manager DPW Environmental Division

Approved by:

Bernhard Weber Site Manager USAG Bavaria - Hohenfels

TABLE OF CONTENTS

(continued) iii

USAG HOHENFELS HWAP RECORD OF REVISIONS

This HWMP must be reviewed and updated at least once every five years. To fulfill this requirement, the following table is provided for tracking revisions to this plan.

Revision No. Date Name and Title Signature Pages Affected

1 09.2008 HMCC versus Veolia (Hazardous Waste

Mangement)

JD 3 Storage and Accumulation

2 02.2010 References new FGS JD Entire Document

3 08.2011 Waste Analysis Plan JD Add new Chapter

4 06.2012 iHWMP JD Complete Revision

5 07.2012 Hazardous Waste Storage Location

JD Add new Chapter

6 08.2012 "eANV" (electronic waste-records procedure)

JD Add new Chapter

7 07.2013 HWSA Operation JD Table 2-2

8 07.2013 HMMP JD 4.1

9 07.2013 Legal Requirement update

JD Entire Document

10 07.2013 HWSA JD Table 2-1

11 07.2013 Contingency Plan JD 11

12 10.2013 DPW ED JD 24

13 10.2013 Appendix 9 JD 89

14 09.2014 2 – Key Personnel MRU 10

15 09.2014 6 - Disposal MRU Table 6-1

16 09.2015 General Update MRU Entire Document

17 10.2016 General Update FM Entire Document iv

18 10.2017 2 – Key Personnel & HW-Data update

FM 10

19 06.2019 General update FM Entire document

20 06.2020 General Update MM/AG Entire document

21 01.2021 Phone numbers Update AG v

SECTION PAGE NUMBER

FACT SHEET .............................................................................................................................. xi

1 INTRODUCTION

2 KEY PERSONNEL

2.1 Waste Management Officer (Betriebsbeauftragter für Abfall)

2.2 Dangerous Goods Advisor (DGA) (Gefahrgutbeauftragter)

2.3 Training of Responsible Individuals (Beauftragte Personen)

2.4 Listing of Key Personnel

3 WASTE ANALYSIS

3.1 Waste Audit Trail

3.2 Roles and Responsibility

3.2.1 DPW ED

3.2.2 Defense logistics agency (DLA)

3.2.3 DPW Utilities

3.2.4 Environmental Officer (EO) and Waste Coordinator (WC)

3.2.5 Contracting Officer’s Representative (COR)

3.3 Establishing an new HWAP/HWSL

3.4 Existing Waste Streams

3.5 Determination of HW Stream

4 STORAGE AND ACCUMULATION

4.1 Hazardous Material Management

4.2 Containers

4.3 Hazardous Waste Generation Locations

4.4 Hazardous Waste Accumulation Point (HWAP)

4.4.1 Definition

4.4.2 HWAP Responsibilities

4.4.3 HWAP Operating Procedures

4.4.4 Determination of the Water Hazard Category for HWAPs

4.5 Hazardous Waste Storage Location

4.5.1 Definition and General Requirements

4.5.2 HWSL Responsibilities

4.5.3 HWSL Operating Procedures

4.6 Hazardous Waste Storage Area (HWSA) Hohenfels

4.6.1 Definition and General Requirements

4.6.2 Description and Operation of the HWSA Hohenfels (SORT Facility) vi

4.6.3 Construction Permit HWSA Hohenfels

4.6.4 Determination of the Water Hazard Category for the HWSA

4.6.5 Waste Transfer

4.6.6 Security Systems

4.6.7 HWSA Closure and HWSA Closure Plans

4.7 Tank Systems

4.8 Inspections

4.8.1 General Requirements

4.8.2 Inspections at Hohenfels HWSA Tank Systems

4.8.3 Inspection Results, Notification and Corrective Action

4.9 Used oil (Altöl) and Battery Management

5 TRANSPORTATION

5.1 Off-Post Transportation Procedures

5.2 On-Post Transportation Procedures

6 DISPOSAL

4.7 Operation of Garrison-operated disposal facility

4.8 Statistical Data

4.9 Tendering of Hazardous Waste

7 DOCUMENTATION

7.1 Hazardous Waste Log

7.2 Hazardous Waste Generators Identification

7.3 Hazardous Waste Identification

7.4 Disposal Documentation

7.4.1 Audit Trail (Prüfweg)

7.4.2 Proof Procedure (Nachweisverfahren)

7.4.3 Accompanying Documentation (Nachweis über durchgeführte Entsorgung)

7.4.4 Proof log (Nachweisbuch)

7.5 Garrison Recordkeeping

7.6 "eANV" (electronic waste-records procedure)

8 TRAINING

9 CONTINGENCY PLANS

9.1 Spill Response Procedures

10 REFERENCES

Table of Appendices vii

LIST OF APPENDICES

Tables, figures, and files referenced below appear in the Appendices portion of the HWAP.

Appendix 1 Garrison Locations of HWSAs and HWAPs (Maps)

Appendix 2 Garrison List of HWSAs and HWAPs

Appendix 3 State-Specific Requirements

Appendix 4 Closure Plans

Appendix 5 Inspection Checklists and Forms

Appendix 6 Hazardous Material Management Program (HMMP)

Appendix 7 Hazardous Waste Training Guidance

Appendix 8 Hazardous Waste Management Compliance Plan

Appendix 9 Hazardous Waste Tracking Sheet viii

LIST OF TABLES

(in the Text Portion of the Plan)

Table 1-1. HWMP Regulatory Cross Reference Matrix

Table 2-1. Hazardous Waste Activities USAG Hohenfels

Table 2-2 Key Garrison Personnel with HW Responsibilities

Table 4-1 Hazardous Waste Generation Locations

Table 4-2. HWSA approved by the German Authorities

Table 4-3. Security and Alarm Systems at HWSA

Table 6-1. Waste Disposal and Waste Services Contracts at USAG Hohenfels

Table 6-2. Waste Disposal and Waste Recycling Facilities used by USAG Hohenfels

Table 7-1. Garrison Recordkeeping

LIST OF FIGURES

Figure 1 Audit Trail

Figure 2 General Sketch Map of a Standard HWAP

Figure 3 SORT Facility Area (including the HWSA)

Figure 4 Sketch Building 125

Figure 5 Sketch Building 105

Figure 6 Disposal Proof and Documentation Procedures for Hazardous Wastes ix

LIST OF ACRONYMS AND ABBREVIATIONS

ADAMAS Analysis Data Management System

ADR European Agreement on International Transportation of Hazardous Goods on Roads

AST Aboveground Storage Tank

CoMaSuSy Compliance Management Support System

DocCon Document Control System

DLA Defense Logistics Agency, formerly known as Defense Reutilization and Marketing Office

DoD Department of Defense

DOL Directorate of Logistics

DPW Directorate of Public Works

« eANV » « elektronisches Abfallnachweisverfahren » = electronic waste-records procedure

EC Environmental Coordinator

EO Environmental Officer

ED Environmental Division

EMS Environmental Management System

EMP(s) Environmental Management Program(s)

EN Entsorgungsnachweis

EWC European Waste Catalogue

FGS Final Governing Standards

HM Hazardous Material

HMCC Hazardous Material Control Center

HMMP Hazardous Material Management Program

HW Hazardous Waste

HWAP Hazardous Waste Accumulation Point

HWMP Hazardous Waste Management Plan

HWPS Hazardous Waste Profile Sheet

HWSA Hazardous Waste Storage Area

LTA Local Training Area

O&M Operations and Maintenance

O/Us Organizations and Units

P2 Pollution Prevention

PPE Personal Protective Equipment

POC Point of Contact

POL Petroleum, Oil, and Lubricants

PPOA Pollution Prevention Opportunity Assessment

RID Regulation Concerning the International Carriage of Dangerous Goods by Rail

SOP Standard Operating Procedure

SPRP Spill Prevention and Response Plan

SW Solid Waste

SWMP Solid Waste Management Plan

U/O Unit/Organization

USAREUR U.S. Army, Europe x

UR USAREUR Regulation

UST Underground Storage Tank

WAP Waste Analysis Plan

WC Waste Coordinator xi

The Hazardous Waste Management Plan

(HWMP) is designed to outline policies and procedures for proper administration, handling, storage, and disposal of hazardous waste.

Furthermore, the HWMP outlines how hazardous waste (HW) practices are tied into daily business practises of the Environmental

Divison under the umbrella of the

Environmental Management System (EMS). Common types of HW found on installations include used batteries, used solvents, brake fluid, battery acid, filters, used oil and fuel, and antifreeze, grease, hydraulic fluid, pesticides, paint, petroleum, oil, and lubribant (POL) contaminated solids (e.g., oily rags); and empty spray cans.

HAZARDOUS WASTE

MANAGEMENT PLAN

FACT SHEET

xii

HAZARDOUS WASTE ACCUMULATION

POINTS (HWAPs) HWAPs are temporary HW accumulation areas at or near the point of generation and under the control of the operator.

When full, a container can only be stored at the HWAP for 5 days. After that, it must be moved to a Hazardous Waste Storage Area (HWSA) or transported for treatment or disposal.

HAZARDOUS WASTE STORAGE AREA (HWSA)

HWSAs are used for HW collection and storage prior to shipment for treatment or disposal. HW can be collected at the HWSA for up to 1 year. A Closure Plan has been prepared for the existing

HWSA.

HAZARDOUS WASTE DATABASES

HW management requires a variety of tracking and documentation. In this regard, several supporting databases have been developed to better focus on environmental compliance and administration.

RECORDS

HW records must be retained as follows:

Inspection Logs: 3 years Turn-in Documents: 3 years HW Log: Until closure HW Proof Log: 3 years from last entry Training Records: 3 years from termination

TRAINING

All personnel involved in the handling, storage, and disposal of HW must receive training before assuming work duties involving HW exposure, and annually thereafter. Verbal operating instructions are given to all employees prior to initiating work with HW.

Final Hazardous Waste Management Plan. USAG Bavaria, Hohenfels 1

1 INTRODUCTION

This integrated Hazardous Waste Management Plan (HWMP) has been developed for USAG Hohenfels to manage hazardous waste (HW) generation, HW handling, and disposal activities.

The Directorate of Public Works (DPW) Environmental Division (ED) for USAG Hohenfels is responsible for development, maintenance, and implementation of this HWMP. The original version from May 2008 was prepared in accordance with IMCOM-E template “Hazardous Waste Management Plan”. This version and respectively the document structure is based on the former template, but instead of attaching dynamic elements (e.g., Appendix 1 “Garrison Locations of HWSAs and HWAPs) to the document, which need to be continuously updated. The document explains how to access the appropriate database and how to receive the appropriate information.

The purpose of an HWMP is to outline policies and procedures for proper and compliant administration, handling, storage, and disposal of HW. FGS Chapter 6 contains cross-references to FGS Chapter 5, Hazardous Materials, and FGS Chapter 7, Solid Waste. Copies of all hazardous waste related chapters of the FGS are available within the document control system (DocCon), which is maintained by DPW ED, at M:\DocCon\B00_FGS. Appendix 9 “Final Governing Standards” of the original 2008 HWMP has been eliminated.

Throughout this HWMP, all subsequent citations from the FGS for Germany are simply referred to as the “FGS.” In addition, it should be noted that the nomenclature for FGS section numbers includes a reference to both the FGS chapter and paragraph (e.g., FGS Section C6.2.2 refers to FGS Chapter 6, Paragraph 6.2.2).

Prior to preparing this HWMP, a Garrison-wide survey of all Hazardous Waste Accumulation Points (HWAPs), Hazardous Waste Storage Area (HWSA), Hazardous Waste Storage Locations (HWSLs) and tank systems storing hazardous wastes was performed, and the GIS-integrated Compliance Management Support System (CoMaSuSy) was updated.

The CoMaSuSy is the updated version of the formerly used Hazardous Substances Information System (HSIS) of the DPW ED. The CoMaSuSy provides information about locations where general hazardous substances, including hazardous wastes, are received, stored or potentially dispensed.

In general, a GIS-application visualizes the HW data and makes it available to the user in accordance with each site-specific location and correlates additional important information (e.g., TUEV reports, manuals, and specific instructions). Different site-specific related information such as Hazardous Material/Waste storage inventories, environmental compliance inspection records, training records, permits, and Environmental Officer (EO) appointments can be retrieved from the database. The available data may be used to support the decision making process in regard to evaluation and meeting environmental compliance standards.

In addition, the CoMaSuSy visualizes documents and cross-references HW related data in accordance with Underground/Aboveground Storage Tanks, HWAPs, HWSA, HWSLs, Hardstands (e.g., refueling sites and filling stations), environmental roles and responsibilities, and corrective action status.

In this respect, ongoing inspections/assessments by DPW ED are continuously performed to update and improve compliance with the provisions of this HWMP. As part of the Environmental Management System (EMS), roles and responsibilities and objectives/targets are described and defined in several HW relevant Environmental Management Programs (EMPs):

• EMP 02 Internal EPAS Inspection

Final Hazardous Waste Management Plan. USAG Bavaria, Hohenfels 2

• EMP 03 Hardstand Inspection

• EMP 04 Quarry Remediation

• EMP 05 Landfill Remediation

• EMP 09 Monitoring End-of-Life-Vehicles

• EMP 10 Hazardous Waste Monitoring

Any nonconformities and deficiencies in accordance with HW related topics will be recorded and tracked with the IPAS Software (Appendix 8 “Hazardous Waste Compliance Plan” is obsolete) The IPAS Software generates “Internal Corrective Action Plan” reports, these reports replace the previously used Hazardous Waste Compliance Plan. The completion status of each defined nonconformity or deficiency is internally controlled through DPW ED. As part of the quarterly EMS Work Group and USAG Bavaria EQCC meetings, the updated completion status of each nonconformity or deficiency is discussed.

The HWMP is used in combination with the Garrison-specific Integrated Solid Waste Management Plan (ISWMP) to effectively manage waste generated by the Garrison, Tenant Organizations, and Units. The ISWMP is available at DPW Operations and Maintenance (O&M) Division, Utilities Branch.

In comparison to the former HWMP 2008 up-to-date information will be available at

Topic HWMP 2008 HWMP 2017

Maps

• HWSA and HWAPs in the Cantonment Areas

• HWAPs in the Training Area (includes LTA Amberg)

• Aboveground storage tanks (ASTs) and underground storage tanks (USTs) in the Cantonment Areas

• ASTs and USTs in the Training Area (includes LTA Amberg)

Appendix 1 CoMaSuSy see Appendix 1

Inventories

• HWSA

• HWAPs

• assigned Environmental

Officers

Appendix 2 CoMaSuSy see Appendix 2

State-Specific Requirements

• A3.1 Storage Tank Requirements in Bayern

Appendix 3 Appendix 3

Final Hazardous Waste Management Plan. USAG Bavaria, Hohenfels 3

• A3.2 Determination of Ordinary and Conventional Facilities in Bayern

• A3.3 Requirements of Water Hazard Category Facilities in Bayern

• A3.4 Tendering Requirements in Bayern

HWSA Closure Plan

• Table A-4.1. Estimated HWSA Storage Capacity

Appendix 4 Appendix 4

Inspection Checklists and Forms

• A5.1. USAG Hohenfels Inspection Checklists

• A5.2. Hazardous Waste Registry

• A5.3. Forms for Hazardous Waste Identification, Tracking and Disposal

• A5.4. Forms for Hazardous Waste Training

Appendix 5 See EMS Training Master Plan &

CoMaSuSy

Hazardous Material Management Program

Appendix 6 See HMMP Grafenwoehr

Hazardous Waste Training Guidance Appendix 7 See EMS Training Master Plan

Hazardous Waste Management Compliance Plan

Appendix 8 See IPAS 7.4 Database and Garrison Corrective Action Plan

Final Governing Standards (FGS) Chapters

Appendix 9 See M:\DocCon\A00_PrgMgmt\A01_E MS\06_Final Governing Standards

FGS

Final Hazardous Waste Management Plan. USAG Bavaria, Hohenfels 4

Table 1-1. HWMP Regulatory Cross Reference Matrix

German FGS Section Description

Applicable Section of

HWMP

Remarks

C6.3.1.1 Hazardous Waste Determination and Characterization

5.3

C6.3.1.2 Hazardous Waste Profile Sheet (HWPS) 6.3

C6.3.1.3 Identification Number 5.2, Appendix 2

C6.3.1.4 Pre-Transportation Requirements 5

C6.3.1.4.3. Audit Trail 5.4.1

C6.2.13. European Waste Code 5.3 CoMaSuSy Adminstration

C6.3.2. Hazardous Waste Accumulation Points (HWAPs)

4.4

C6.3.2.2 Storage Limitations for HWAPs 4.4

C6.3.2.3 Management of Containers at HWAPs 4.2

C6.3.2.4/

C6.3.5.1

Recordkeeping Requirements for HWAPs 5.1 / 5.3 / 5.5

C6.3.2.5 Personnel Training for Managing HWAPs 6

C6.3.3 Hazardous Waste Storage Areas (HWSA) – Technical Requirements

4.6

C6.3.3.2 Design and Operation of HWSAs (Duration of Waste Storage in HWSAs)

4.6

C6.3.3.3 Waste Analysis and Verification 4.6.5

C6.3.3.4 Security 4.6

C6.3.3.4.2 Security System Design 4.6.6

C6.3.3.8 General Inspection Requirements 4.8

C6.3.3.10 Storage Practices 4.6 / 4.2

Table 1-1. HWAP Regulatory Cross Reference Matrix

Final Hazardous Waste Management Plan. USAG Bavaria, Hohenfels 5

German FGS Section Description

Applicable Section of

HWMP

Remarks

C6.3.3.11 Closure and Closure Plans 4.6.7 / 6

C6.3.4.1 Container Handling and Storage 4.2

C6.3.4.2.4 Rainwater Captured in Secondary Containment – Inspection and Testing Requirements

4.6

C6.3.4.3 Special Requirements for Ignitable or Reactive Waste

4.2

C6.3.4.4 Special Requirements for Incompatible Wastes 4.2

C6.3.5 Recordkeeping Requirements 4.4 / 5.4.1 / 5.5

C6.3.5.2 Hazardous Waste Log 5.1

C6.3.5.3 Availability of Hazardous Waste Log 5.1

C6.3.5.4 Inspection Logs 4.8 / 5.5

C6.3.5.5 Manifests 5.5

C6.3.5.6 Waste Analysis/Characterization Records 5.5

C6.3.6 Contingency Plan 6

C6.3.7 Tank Systems 4.7 / 4.8

C6.3.7.2 Response to Leaks or Spills and Disposition of Leaking or Unfit-For-Use Tank Systems

4.7

C6.3.7.2.3 Spill Notification Procedures 4.7

C6.3.7.3 Closure 4.6.7

C6.3.8 Standards for the Management of Used Oil and Batteries

4.9

C6.3.10 Hazardous Waste Training 6

Table 1-1. HWAP Regulatory Cross Reference Matrix

Final Hazardous Waste Management Plan. USAG Bavaria, Hohenfels 6

German FGS Section Description

Applicable Section of

HWMP

Remarks

C6.3.11 Hazardous Waste Disposal 6 / 4.7

C6.3.12 Tendering of Hazardous Waste 4.9

C6.3.13 Permitted Transportation and Disposal Companies

C6.3.14 Waste Management Officer 2.1 / 2.4

C6.3.16 Daily Removal of Hazardous Waste to HWAP or HWSA

4.4

Final Hazardous Waste Management Plan. USAG Bavaria, Hohenfels 7

2 KEY PERSONNEL

This section details the Garrison’s key personnel with regard to HW management. Table 2-2 in Section 2.4 provides contact information for key personnel.

2.1 WASTE MANAGEMENT OFFICER (BETRIEBSBEAUFTRAGTER FÜR ABFALL)

A waste management officer must be assigned if specific hazardous waste activities, as indicated in Table 2-1, occur within the Garrison. If any of these activities occur within the Garrison, the Garrison must have an appointed Waste Management Officer.

Table 2-1. Hazardous Waste Activities USAG Hohenfels

Hazardous Waste Activity Occurs within USAG Hohenfels?

Yes No

Hazardous waste storage facility (SORT Facility) including Hazardous Waste Storage Area (HWSA) X*

Hazardous waste disposal facility X

Landfill X**

Incinerator X

Hospital and/or clinic X***

Plant for chemical or physical treatment of HW with a throughput of more than 0.5 metric tons (500 kg) per hour X

* The permit for the SORT Facility (HWSA) stipulates requirements for the training and the qualification of personnel operating the SORT Facility but does not require a Waste Management Officer (Betriebsbeauftragter für Abfall). HWSA personnel is trained in accordance with TRGS 520, an annual refresher is required.

** Two landfills exist on post, both were closed down in 1997/1998. The receiving area of the Neuhaus landfill is used to temporarily store empty recyclable containers.

*** Hospital/Clinic is operated by MEDDAC not Garrison Command. MEDDAC has assigned HW responsibilities to trained personnel and has implemented a HW Contingency Plan.

Due to the activities performed within the Garrison, USAG Hohenfels has appointed personnel, at several levels, who are responsible for the management of solid waste and hazardous waste.

Contact information for the Waste Management Officer (Betriebsbeauftragter für Abfall) and personnel with assigned responsibilities for waste management is provided in Table 2-2 in Section 2.4.

2.2 DANGEROUS GOODS ADVISOR (DGA) (Gefahrgutbeauftragter)

HW that is transported off-post is considered dangerous goods. As such, USAG Hohenfels is required to have an appointed Dangerous Goods Advisor (DGA/Gefahrgutbeauftragter). Contact information for this individual can be found in Table 2-2 in Section 2.4. The DGA’s office is located off site in Heidelberg.

Final Hazardous Waste Management Plan. USAG Bavaria, Hohenfels 8

2.3 TRAINING OF RESPONSIBLE INDIVIDUALS (BEAUFTRAGTE PERSONEN)

The Garrison performs transport of HW which is considered dangerous goods. USAG Hohenfels has identified responsible personnel to oversee the transport of HW that is considered dangerous goods. The responsible individuals are authorized to give instructions and receive annual training.

Contact information for the responsible individuals and the individual/organizations that providing training is provided in Table 2-2 in Section 2.4.

2.4 LISTING OF KEY PERSONNEL

USAG Hohenfels key personnel are listed in Table 2-2. The contact information contained herein is updated, as appropriate, to reflect modifications in the Garrison’s operations.

Regarding waste analysis, key personnel who deal with HW are divided into the following groups:

• Group 1“Contract Management Group”: Activities that may generate HW and a pre-arrangement (e.g., waste disposal contract) needs to be established to ensure a safe HW disposal. This includes the Contracting Officer’s Representatives (CORs), who deal with off-site shipments and disposal of wastes, as well as any personnel dealing with maintenance and emergency preparedness operations. Environmental reviews of projects are crucial to determine if disposal activities need to be handled under the provision of HW management.

• Group 2 “Disposal Management Group”: Preparation of on-site and off-site shipments at the unit/organization (U/O) level. Includes the preparation of orders and the documentation of all required records.

• Group 3 “Training Group”: Internal verification that personal is appropriately trained.

• Group 4 “Disposal Group”: Waste Management Contractors.

Table 2-2. Key Garrison Personnel with HW Responsibilities

Management Group

Group Position/Task Unit/ Activity Name Telephone

Number

(DSN/CIV)

Email Address

1 DPW ED Team lead DPW ED Ms. Silke

Bornemann

DSN 522-8300/

(09472) 708 8300 silke.bornemann.ln@mail.

mil

Waste Management Officer (Betriebs-beauftragter für Abfall)- SORT Facility

Krätz- Contractor

Mr. Arbusauskas DSN 522-4887 g.arbusauskas@kraetz-parsberg.de

1 HWSA

Süd-Müll GmbH

& Co KG

Andreas Hallmann

Justin Percy

+49 (0) 6233 7701-

(0175) 2993 064 a.hallmann@sued-muell.com j.percy@sued-muell.com mailto:silke.bornemann.ln@mail.mil mailto:silke.bornemann.ln@mail.mil mailto:g.arbusauskas@kraetz-parsberg.de mailto:g.arbusauskas@kraetz-parsberg.de mailto:a.hallmann@sued-muell.com mailto:a.hallmann@sued-muell.com

Final Hazardous Waste Management Plan. USAG Bavaria, Hohenfels 9

Landfills (Albertshof, Neuhaus), Rock Quarry

Site manager

USAG

Hohenfels

Mr. Bernhard Weber

DSN 522-8000

(09472) 708 8000 bernhard.weber.ln@mail.

mil

Dangerous Goods Advisor (DGA)

HW transportation

HQ USAREUR

Unit 29351

Mr. Ehrenfried Dengler(retiring)

DSN 537-0396

(06111)

435370396 ehrenfried.dengler.ln@ mail.mil

MEDDAC Waste Coordinator

MEDDAC

Health Clinic

Carmen Lenz

CPT Charles Pham

DSN 314- 590 -

DSN 590-3912

carmen.h.lenz.ln@mail.mil charles.q.pham.mil@mail.mil

AAFES Gas Station Waste Coordinator

AAFES Gas Station

Hohenfels Building: 392

Mr. Keith Dreibelbis

DSN 522-2727

(09472) 83 2727 dreibelbisk@aafes.com

SW &

Construction/Demoliti on Debris storage

DPW

Operations & Maintenance

O&M

Mr. Michael Schlosser

DSN 522-8200/

(09472) 708 8200 micheal.j.schlosser3.ln @mail.mil

Emergency Response

DES Fire & Emergency

Services Mr. Günter Stöckl

DSN 522-2858/

(09472) 83 2858 guenter.a.stoeckl.ln@m ail.mil

1 Construction DPW Engineering

Division Rogerio Santovito

DSN 522-8400/

(09472) 708 8400 rogerio.santovito.ln@m ail.mil

1 Holding Yard FMWR Auto Crafts Shop

Mr. John Kolpack

DSN 466-2960/

(09472) 708 2960 john.e.kolpack.naf@mail.

mil

1 Training Activities JMRC n/a (temporary) n/a n/a

Disposal Management Group

Group Position/Task Unit/ Activity Name Telephone

Number

(DSN/CIV)

Email Address

2 Maintain HW Logs DPW ED Mr. Robert Braun

DSN 522-8302/

(09472) 708 8302 robert.braun2.ln@mail.mil mailto:bernhard.weber.ln@mail.mil mailto:bernhard.weber.ln@mail.mil mailto:ehrenfried.dengler.ln@%20mail.mil mailto:ehrenfried.dengler.ln@%20mail.mil mailto:carmen.h.lenz.ln@mail.mil mailto:dreibelbisk@aafes.com mailto:micheal.j.schlosser3.ln@mail.mil mailto:micheal.j.schlosser3.ln@mail.mil mailto:guenter.a.stoeckl.ln@mail.mil mailto:guenter.a.stoeckl.ln@mail.mil mailto:rogerio.santovito.ln@mail.mil mailto:rogerio.santovito.ln@mail.mil mailto:john.e.kolpack.naf@mail.mil mailto:john.e.kolpack.naf@mail.mil mailto:robert.braun2.ln@mail.mil

Final Hazardous Waste Management Plan. USAG Bavaria, Hohenfels 10

DPW Utilities

Vacant

Mr. Norbert Kolb

(SORT

Coordinator)

DSN 522-2672/

(09472) 708 2672 norbert.e.kolb.ln@mail.mil

Update HW Profile Sheets

DPW ED Mr. Robert Braun 522-8302/

(09472) 708 8302 robert.braun2.ln@mail.mil

Maintain Disposal Records (Disposal Contract, Begleitschein, and Übernahmeschein)

DLA

Ms. Ursula Lee

Mr. Michael Lapine

475-6384 0162-2731191

475-8442 01735345959 ursula.lee.deu@dla.mil

Michael.Lapine@dla.mil

MEDDAC

Health Clinic

Carmen Lenz

CPT Charles Pham

DSN 314-590 -

DSN 590-3912

carmen.h.lenz.ln@mail.mil charles.q.pham.mil@mail.mil

FMWR Auto Crafts Shop

Mr. John Kolpack

DSN 466-2960/

(09472) 83 2960 john.e.kolpack.naf@mail.

mil

Electronically Sign Disposal Records (Begleitschein, gold copy)/(Garrisons HW representative) – Card Holder

DPW ED Mr. Robert Braun 522-8302/

(09472) 708 8302 robert.braun2.ln@mail.mil

DPW ED Vacant n/a N/A

Group Training Group

3 Provide Training

DPW Utilities

Vacant

(SORT

Coordinator)

DSN 522-2672/

(09472) 708 2672 norbert.e.kolb.ln@mail.mil

DPW ED Ana Gonzalez 522-8305/

(09472) 708-8305 ana.a.gonzalezmartinez.ctr@ mail.mil

MEDDAC

Health Clinic

Carmen Lenz

CPT Charles Pham

DSN 314-590 -

DSN 590-3912

carmen.h.lenz.ln@mail.mil charles.q.pham.mil@mail.mil

HMCC

Vacant

Mike Donahue

Dimitris (WOOD) n/a N/A mailto:norbert.e.kolb.ln@mail.mil mailto:robert.braun2.ln@mail.mil mailto:ursula.lee.deu@dla.mil mailto:Michael.Lapine@dla.mil mailto:carmen.h.lenz.ln@mail.mil mailto:john.e.kolpack.naf@mail.mil mailto:john.e.kolpack.naf@mail.mil mailto:robert.braun2.ln@mail.mil mailto:norbert.e.kolb.ln@mail.mil mailto:carmen.h.lenz.ln@mail.mil

Final Hazardous Waste Management Plan. USAG Bavaria, Hohenfels 11

Maintain Training Records

DPW ED maintains records for the training provided by DPW ED.

The O/Us are required to file training records in accordance with their procedures.

As these filing procedures vary from unit to unit, it is not reasonable to implement a centralized training record system. Maintaining personnel training records is also addressed in the Garrison’s Environmental Management System (EMS) Procedures and in the EMS Training Master Plan.

Disposal Group

Group Function Contractor Name and Address Phone / Fax Transporter Number

4 Solid Waste Disposal

Mr. Georg Arbusauskas (SORT Facility Manager) Krätz GmbH An der Autobahn 7 92331 Parsberg

DSN 522-4887

(09492) 600069 I574 T1056

4 HWSA Operation

Süd-Müll GmbH & Co KG

Gerolsheimer Strasse

67258 Hessheim, Germany

(0151) 5441 n/a

HW Transport and Disposal

Städtereinigung Rudolf Ernst GmbH & Co. KG

Aha 200

91710 Gunzenhausen

Herr Kalcher (09831) 800646

I577 S0004

4 MEDDAC Waste Remondis Medison GmbH Brunnenstrasse 138 D-44536 Luenen

(02306) 106199 E97880796

Sludge Removal

Mr. Georg Arbusauskas (SORT Facility Manager) Krätz GmbH An der Autobahn 7 92331 Parsberg

DSN 522-4887

(09492) 600069 I574 T1056

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3 WASTE ANALYSIS

The general purpose of waste analysis is to ensure that generated waste is identified, characterized, and recycled or disposed of in accordance with host nation requirements, the Final Governing Standards for Germany, and best management practices. This chapterreplaces the Waste Analysis Plan (WAP).

The Garrison’s goals are:

• to minimize Garrison-wide costs associated with waste management services and waste disposal.

• to ensure that the generator is aware of his expertise, competency and responsibility to classify generated wastes.

• to implement, establish and maintain a waste verification/classification process beginning at the point of origin (i.e., with the activity that generates the waste and the personnel responsible for this activity).

• to assist, support and guide each stage of the process until the waste is appropriately recycled or disposed of in an economically feasible manner.

Waste analysis is continuously changing due to sensitive or difficult waste analysis procedures and processes that are routed through different key personnel as listed in Table 2-2. Therefore, the application of EMPs under the umbrella of EMS is used as tracking tool. However, any gaps detected in the waste analysis process should be worked out and added in a timely manner to the appropriate EMP, which means, procedures must be reviewed or adopted to specific procedural or legal requirements. Furthermore, responsible persons (e.g., DPW Utilities or waste generators) shall review the corresponding portions of their EMP. This includes continuous reporting to key personnel on the Environmental Quality Control Committee (EQCC) or through appropriate channels. Measurable EMS objectives, targets, and competency trainings need to be established. Furthermore, Pollution Prevention (P2) opportunities shall be assessed and feasibility studies shall be conducted and implemented accordingly as part of the Pollution Prevention Opportunity Assessment (PPOA).

All facilities and activities that generate any solid or HW throughout the Garrison are subject to waste analysis. The Integrated Solid Waste Management Plan (ISWMP) shall be used as an additional source of the Garrison’s overall waste management framework.

Waste analysis results will be captured, filed and administrated at the centralized Analysis Data Management System (ADAMAS) within DPW ED. The database lists all sites which need to be analytically monitored (e.g., soil sampling locations, basins, soil piles, waste containers, etc.).

Each site can be displayed in GIS showing site and sampling points.

The database provides threshold values as well as parameter scopes for analyzing wastes as outlined in legal requirements and guidelines, Host Nation permits, and on-site relevant guidance.

The data base allows for the querying of historic and current analytical data which offers the opportunity to evaluate HW contamination by individual case. These data base features also offer a more holistic approach to pollution prevention because it allows the user to focus on the root cause of the pollution. All relevant current and historic information are linked to the project funding source, sampling objectives, measures taken, and points of contacts.

3.1 WASTE AUDIT TRAIL

Any potential waste stream throughout the Garrison must be classified by appropriately competent personnel. The classification of the waste stream always starts at the point of origin, for example at the generator activity. The generator must competently classify their wastes. If the

Final Hazardous Waste Management Plan. USAG Bavaria, Hohenfels 13 generator determines, that they are exceeding his competency further guidance and/or assistance should be sought.Each waste generator shall be trained in respect to their specific waste streams.

3.2 ROLES AND RESPONSIBILITY

3.2.1 DPW ED

DPW ED inspects waste generation, interim storage areas and designed storage locations (e.g., HWAP, Health Clinic, FMWR Holding Yard) for legal compliance during scheduled bi-annual or random Environmental Performance Assessment System (EPAS) inspections. Detected non-compliances are tracked, documented, managed, and processed within the EPAS tracking. In addition, the EMS aspects worksheet for each Unit/Organization (U/O) is annually reviewed and updated within the EMS database in accordance with the generation, storage and shipment of any wastes. An identified EMS significant aspect in regard to SW/HW will result in the implementation of an EMP.

Due to legal requirements, DPW ED continuously investigates suspicious waste streams at all U/Os or at the point of origin to ensure the safe and legal disposal or treatment of the waste. This can also require taking appropriate waste samples for laboratory testing or visual classification (see ADAMAS). Sampling will also occur when insufficient information is provided to prepare or comply with ADR, the waste is unknown, or non-routine waste streams are generated.

DPW ED collects all inventories of HW waste streams in cooperation with the HWSA/HWAP/HWSL operator or waste generator. Once HW exceeds certain amounts at assigned storage areas, a HW pick up is requested. A HW pick up request is forwarded to the Defense Logistics Agency (DLA) for coordination. HW pickups are distinguished as:

• SORT pickup: HW off post shipment of Garrison-wide accumulated HW at the HWSA with onsite DLA representative and Garrison representative for signature.

• Direct pickup: HW off post shipment of accumulated HW in site specific AST/UST, sludge basins, etc. with onsite DLA representative and Garrison representative for signature.

• Others: Internal HW pick up, where the generator either does not have the capability to transport the HW to the SORT Facility or does not have the appropriate waste container.

Waste management services should be requested and include information on equipment needed (e.g., pump truck).

• Waste Management Services: Internal HW pick up of solid HW or liquid HW in manageable containers from HWAPs, HWSL, etc. The DLA representative does not need to be onsite. Waste manager will sign at DPW ED. DPW ED prepares and hands over a pickup schedule based on the reported filling levels from the HW generators.

Recorded pickup levels will be forwarded for documentation to DPW ED by the end of the working day.

For tracking purposes DPW ED also tries to gather Garrison-wide HW data for integration into environmental management and planning activities. In this respect the HW media manager has the following responsibilities:

• to encourage the development and introduction of environmentally compatible, low-waste-producing processes, including processes for the avoidance, proper and safe recovery, or environmentally compatible disposal of waste.

• to encourage the development and introduction of environmentally compatible, low-waste-producing products, including processes for reuse, recovery and environmentally compatible disposal upon completion of use of these products.

Final Hazardous Waste Management Plan. USAG Bavaria, Hohenfels 14

• to cooperate in the development and introduction of above-mentioned processes, especially by studying the relevant processes and products using criteria of closed substance cycle waste management and/or disposal.

• to seek/encourage improvements of relevant processes in facilities in which waste is recovered or disposed.

• to encourage all U/Os to retrieve suitable disposal documents as a hard copy (especially these U/Os which are described in table 4.1 and identified as waste disposal contract authority).

• to issue the annual internal HW tracking report (“HW Tracking” Sheet - Appendix 9).

• to track and update all retrieved disposal documents into the HMMS.

• to prepare an annual HW balance considering all generated HW/SW streams (not only waste processed through DLA).

3.2.2 DEFENSE LOGISTICS AGENCY (DLA)

The DLA Disposition Services manages the disposal of hazardous property for DoD activities. At USAG Hohenfels, almost all HWs are collected at the HWSA at Camp Nainhof for offsite treatment or disposal. DLA oversees the HW contract and coordinates pickups with DPW ED.

Prior to March 2011, HW disposal/pick up documentation was signed by a representative of DLA.

In March, 2011 the Garrison appointed representatives (members from USAG Hohenfels HHD and/or DPW ED) to sign for disposal pickups (see Card Holder at table 2-2).

In the case of a newly occurring HW stream, DLA and DPW ED coordinate classification and the preparation of an appropriate HW profile sheet (HWPS). DLA will add the new HW as line item into the HW disposal contract.

DLA tracks HW off-site shipments within a database. The database is accessible to DPW ED.

DPW ED personnel are able to generate an annual HW report with all wastes, that are processed through the DLA contract.

3.2.3 DPW UTILITIES

The “Trash Separation Policy for the United States Army Garrison Hohenfels” promotes the usage of the SORT Facility for trash collection, recycling and composting opportunities. DPW Utilities oversees the solid waste contract and DPW Utilities contractors operate a SORT Facility at Camp Nainhof, Bldg. 105 for numerous recyclables and refuse. The solid waste contractor provides weekly collection of trash (refuse) and recyclable materials to USAG Hohenfels residences. Collection islands (igloos) for recyclables are also distributed throughout the Garrison. Further details can be found in the Integrated Solid Waste Management Plan (ISWMP).

3.2.4 ENVIRONMENTAL OFFICER (EO) AND WASTE COORDINATOR (WC)

Each U/O at the Garrison is required to appoint an Environmental Officer (EO) or Waste Coordinator (WC). The duties of the appointee are to advise U/O personnel on questions regarding waste management/disposal and to act as a so-called “waste coordinator” (see table 2- 2 group 2). He/she is authorized and obligated:

• to supervise compliance with the requirements of the “Trash Separation Policy for the United States Army Garrison Hohenfels”, as well as the fulfillment of existing conditions and restrictions.

• to control, at regular intervals, the U/O’s facilities and the type and nature of the waste which occurs in the facilities or which is recycled or disposed.

• to provide information regarding detected insufficiencies and to make proposals for measures to eliminate these insufficiencies.

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• to forward generated HW amounts via email to DPW ED “usarmy.bavaria.id-europe.list.hohenfels-dpw-emo@mail.mil”

• to inform appropriate Garrison personnel and chain of command if he detects that current waste handling procedures could interfere with the Garrison’s interests, taking into account the laws and statutory ordinances applying to the avoidance, recovery and disposal of waste.

3.2.5 CONTRACTING OFFICER’S REPRESENTATIVE (COR)

A COR (see table 2-2 group 1) has the responsibility/authority to monitor all aspects of the day-to-day administration of a contract. In this respect, the COR maintains SW/HW documentation and records (e.g., Begleitschein, disposal documents, weight tickets, etc.) pertinent to final clearance.

Any waste disposal or treatment activities within the scope of a contract shall be discussed and monitored in close collaboration with the DPW ED. However, prior to execution each contract shall pass an environmental review (ER) conducted through the DPW ED. The waste audit trail, recycling methods, and the potential generation of HW shall be a main focus of the ER.

3.3 ESTABLISHING AN NEW HWAP/HWSL

DPW ED will contact the new O/U and will define, as part of the implementation process, EMS environmental aspects. The EMS environmental aspects reflect potential waste streams based on specific operations and storage of hazardous substances. Potential wastes being turned in as HW must be accompanied by a site-specific HWPS. DPW ED will assist generators with preparation of paperwork and appropriately setting up HWAP/HWSL. An “unknown waste stream” shall be handled as described in the following paragraph.

3.4 EXISTING WASTE STREAMS

Existing (known) waste streams do not typically need to be analyzed. However, if a known waste stream appears to be different from the waste stream received in the past, or if there is a doubt that the waste received at the HWSA, HWAP or HWSL matches the accompanying documentation, the waste will be analyzed. The analytical parameters are to be determined on a case-by-case basis that depends on the waste generation process, the waste characteristics, and the recycling/disposal method.

3.5 DETERMINATION OF HW STREAM

The scheme “Audit Trail”, Figure 1,describes the course of actions for analyzing unknown or undefined waste streams. The “Audit Trail” must be separated into two procedural audit trails (see Figure 4-1. Audit Trail). The first step of “Audit Trail” describes the preliminary audit trail, where the generator onsite needs to react appropriately. The second step of “Audit Trail” describes the more specific classification audit trail, where coordination by the DPW ED is essential.

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Figure 1. Audit Trail.

The Preliminary Audit Trail is subdivided into several intermediate steps, as followed:

Pre-step 1: If onsite personnel are not able to classify the waste stream in accordance with the “Trash Separation Policy for the United States Army Garrison Hohenfels” or in accordance with an established HWPS, then additional action must be taken.

If the detected unknown/undefined waste is determined not likely to present an acute threat to human health or imminent danger to safety or the environment, the on-site personnel can continue as follows, otherwise he or she needs to follow the instruction of the Red Plan.

Pre-step 2: Onsite personnel will provide information regarding the occurrence of an unknown/undefined waste stream to the on-site appointed EO, WC or supervisor.

Pre-step 3: If the EO/WC is not able to classify unknown/undefined waste stream, the on-site EO/WC/supervisor will take security measures in accordance to pollution prevention goals, e.g., storage of unknown waste in an appropriate container in an HWAP or on a secondary containment to protect waste against inclement weather.

Pre-step 4: The onsite EO/WC/supervisor will promptly inform the DPW ED.

Pre-step 5: The DPW ED media manager or appropriate personnel will conduct an onsite assessment to ensure that appropriate security measures are taken.

Pre-step 6: Furthermore, the DPW ED media manager or appropriate personnel will start the verification or classification process of the unknown waste stream. In this respect they will use Table 4-1 “Hazardous Waste Generation Locations” to verify disposal contract.

Pre-step 7: As soon as the disposal contract authority is verified Table 2-2 “Key Garrison Personnel with HW Responsibilities” must be consulted to determine the adequate POC.

Pre-step 8: Until further notice the unknown waste stream will remain at the secured location.

Pre-step 9: The “unknown/undefined waste” must be labeled and the following information must be also posted: date of detection, assessments conducted through name of person, and phone number of appropriate DPW ED contact.

Final Hazardous Waste Management Plan. USAG Bavaria, Hohenfels 17

The preliminary procedure of “notice of unknown waste stream” will be added to the Garrison environmental competency training program.

The Classification Audit Trail is subdivided into several intermediate steps, as followed:

Class-step 1: The DPW ED will start the waste classification process by using ED contracts available for sampling and laboratory analysis.

Class-step 2: In accordance with the preliminary investigation DPW ED will determine and authorize the necessary sampling and analysis methods.

Note: The decision process of sampling and analysis methods will be separately defined in an additional EMP “Sampling and Analysis Methods”.

All relevant decisions are documented within the DPW ED project management folder (DocCon, M:\DocCon). In some cases, DPW ED shall follow already established procedures, which are also including determinations of sampling and analysis methods.

Class-step 3: In general, sampling and analysis of unknown and undefined waste shall be performed by independent and accredited testing bodies or by bodies approved by the competent authorities.

The samples for analysis shall be collected in accordance with established guidelines (see EMP “Sampling and Analysis Methods”).

Class-step 4: The parameters shall be measured in accordance with the state-of-the-art procedures for solids or eluates (liquids).

Class-step 5: In general, analysis methods for solids shall meet analysis standards.

Class-step 6: In general, analytical procedures for eluates (liquids) shall conform to referenced standards.

Class-step 7: After waste analysis is completed, a written report (which refers to the laboratory results) and the laboratory results will be issued to the DPW ED.

Class-step 8: In accordance with the written report, the waste stream will be partially classified by comparison between solid waste streams, HWPSs or current contracts, which also include specific disposal services. If the sampled waste does not match any of the mentioned disposal channels, a new HWPS must be generated.

Class-step 9: If a new waste stream is generated further analysis shall be conducted to classify the unique HW.

Class-step 10: Prior to opening a new hazardous waste profile, the new waste profile must be assigned to a disposal contract and/or any other contract which ensures a legal deposition (including transportation, storage, treatment or disposal).

Class-step 11: As soon as the waste is assigned to the appropriate contract, the COR must ensure that funds are available.

Class-step 12: If funds are available, waste disposal shall be requested through the COR and all analytical results must be forwarded to the waste management company for classification.

Prior to disposal, the waste management, disposal/treatment and transportation Company (ies) shall verify legality and provide appropriate documentation/permit/certification/calibration/disposal limits to the waste generator (COR).

Class-step 13: Disposal documents will be signed and filed by the COR or his representative and disposal documents will be filed in accordance with FGS requirements.

Class-step 14: DPW ED will always receive a hardcopy or an electronic copy for tracking purposes.

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4 STORAGE AND ACCUMULATION

USAG Hohenfels operates one HWSA located at the SORT Facility (Bldgs #105 and #125), and approx. 50 HWAPs that are spread over the cantonment area, the Hohenfels Training Area, and the Local Training Area (LTA) Amberg. The HWSA is operated by a waste disposal contractor on behalf of DPW ED.

The HWAP operator is primarily responsible for keeping up compliance standards at locations where HW is generated, accumulated, and stored. The generator will report, via an informal E-mail, HW inventories, filling levels and detected non-compliances to DPW ED. Occasionally, and when necessary, DPW ED personnel conduct environmental compliance spot checks at the HWAPs. Reported data (e.g., HW filling levels, comments, etc.) are entered into the CoMaSuSy and internal HW pickups are coordinated, through DPW ED personnel, accordingly. Annual internal HW generation per waste stream or location can be retrieved from the CoMaSuSy (see Appendix 1 ”Internal HW Tracking with CoMaSuSy”). The HWAP operator is usually the unit’s Environmental Officers (EOs) or Waste Coordinator (WCs). As such, are also responsible for the documentation at the unit/organization (O/U) level.

The CoMaSuSy also provides updated information that indicates where storage areas are located throughout the Garrison. In addition, pictures of HWAPs, HWLSs and controlled documents are linked to each location. The CoMaSuSy is located at the following filepath “M:\Databases\CoMaSuSy” and the example below provides some rudimentary instructions for navigating withing the CoMaSuSy.

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Example of How to Access information within CoMaSuSy.

HWAP Information

1. Open CoMaSuSy.

2. Click the HWAP button in the Title Ribbon.

3. Select an HWAP (e.g. “AutoCraftsShop1_HWAP”).

4. Under “Entities at USAG Hohenfels” select options such as “Open overview map” to retrieve information about where storage areas are located, “Open photo folder” to retrieve pictures, and “Open document folder” to retrieve controlled documents.

5. Double click on an HWAP name to review and update various waste streams, repository volues, and enter pickup data.

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EO and WC Information

To generate list of current EOs/WC

1. Open the Organigram by clicking the Organigram button.

2. Right click “Hohenfels Training Area”and select “Export Training-, Assessment Status to Excel”. This will export a list containing current EO/WC as well as the dates of their last EO training, Staff Training, and Assessment.

Linking to the EMS Database

There is a link withing that CoMaSuSy that allows direct access to the EMS Database.

To Access this Link

1. Open the CoMaSuSy

2. Click the EMS Database within the Title Ribbon.

3. The EMS Database will open in an additional window.

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4.1 HAZARDOUS MATERIAL MANAGEMENT

DOL Grafenwöhr provides hazardous material management and technical expertise for executing the Hazardous Material Management Program (HMMP) within the Bavarian Military Community.

Detailed information on the HM related services and HMMP components is provided in the Garrison Environmental Standard Operating Procedure Annex M.

In case of reuse of HM, turn in, or extension of shelf life procedures contact the HMRIC at DSN 476-2512 in Vilseck.

4.2 CONTAINERS

The HW contractor typically provides the containers for HW transportation. Additional empty HW containers are provided by the contractor and are stored at the HWSA in Bldg. 125. The contractor is responsible for labeling all transport containers. The HW Management Officer must ensure that all containers provided by the HW disposal contractor and the HW service contractor meet the requirements of ‘The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR)’,…