Attachment 12 - Lajes Field HW Mgmt Plan (HWMP).pdf

HAZARDOUS WASTE MANAGEMENT PLAN

U. S. AIR FORCE HAZARDOUS WASTE MANAGEMENT PLAN

FOR OVERSEAS INSTALLATIONS

Lajes Field

11 May 2018

ABOUT THIS PLAN

This installation-specific Environmental Management Plan (EMP) is based on the U.S. Air Force’s (AF) standardized Hazardous Waste Management Plan (HWMP) template for overseas installations. This plan is not an inventory of all hazardous waste (HW) requirements and practices. External resources, including Air Force Instructions (AFIs); AF Playbooks; Final Governing Standards (FGS); and permit requirements, are referenced.

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 hazardous waste management program manager and/or the Air Force Civil Engineer Center (AFCEC) Regional Support Branch (RSB) appointed to support this installation.

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

TABLE OF CONTENTS

DOCUMENT CONTROL

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 Hazardous Waste Management

7.6 Transportation

7.7 Turn In/Disposal

7.8 Inspection

7.9 Waste Minimization

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 Locations

Appendix C – Sample Forms

DOCUMENT CONTROL

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).

Record of Updates

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

1 Changes in waste generation and management practices to reflect the base streamline process

3/27/2017 65 ABG CC

2 Updated to latest standardized template and comprehensively updated all installation-specific sections and appendices.

05/11/2018

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Record of Annual Review – In accordance with (IAW) AFI 32-7042, Waste Management, this plan is reviewed annually by the Environmental Management System (EMS) Cross Functional Team (CFT).

Formatting and administrative changes should be noted in the above 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

Record of EMS CFT Annual Review

Review Date Review Participants Notes/Remarks Result in Plan Update? (Yes or No)

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1.0 OVERVIEW AND SCOPE

This HWMP contains procedures for management of HW. In addition to the FGS requirements, AFI 32- 7042, Waste Management, acts as a main driver for the HWMP. The HW Playbook serves as supplemental guidance to this plan.

Installation Supplement – Overview and Scope

NOTE: This plan does not address clinical wastes, radioactive wastes, non-dangerous special waste or explosives.

Applicability to Lajes Field

This plan was established to implement an effective and comprehensive HW management program at Lajes Field. It establishes organizational responsibilities, generator responsibilities, and turn-in procedures to ensure all tasks are being carried out according to AF, European Union (EU) and Final Governing Standards Portugal (FGS-P) requirements and operating procedures.

All 65 Air Base Group (ABG) personnel, including tenant activities and Temporary Duty (TDY) personnel, will comply with the responsibilities and procedures stipulated herein, and will support this plan's implementation, expansion, and update as deemed necessary by the 65 ABG Commander as Chair of the ESOHC.

65 CES/CEIE Environmental Office Annual Review Procedures

The installation environmental office (65 CES/CEIE) annually conducts an internal review of the HWMP.

The following sections and tables must be reviewed, usually prior to the annual review by the EMS CFT, to ensure accuracy and consistency.

• Section 2 – Installation Profile

• Section 4 – General Roles and Responsibilities

• Section 8 – Installation References

• Appendix B – Hazardous Waste Locations (HWAP/HWSA)

• Appendix C – Sample Forms

65 CES/CEIE review of additional sections of the HWMP may also be required when any substantive regulation change or update to related management and contingency plans occurs (such as the Spill Prevention and Response Plan).

2.0 INSTALLATION PROFILE

Installation Profile

Scope of Plan All 65 ABG personnel, including tenant activities and TDY personnel.

Office of Primary Responsibility

(OPR)

65 CES/CEIE has overall responsibility for implementing the HW management program and is the lead organization for monitoring compliance with regulations

HW Program Manager Carla Oliveira

Alternate HW Program Manager Duarte Fainha

Emergency contacts

Waste registration numbers

FGS regulatory references

Local regulatory agencies

Local regulatory references

Approved HW disposal contractors

HW storage areas

HW accumulation time limits

HW generator reporting frequency

On Installation: 911

Terceira’s Environmental Services: 295-206-310

Local Community Emergency: 112

Host Nation ID number: 567

FGS-P November 2017

Ministério do Ambiente, Secretaria Regional da Agricultura e Ambiente and Direcção Regional do Ambiente

Decreto Legislativo Regional 29/2011/A, Decreto Legislativo Regional 24/2012/A

DLA-DS will be used as the primary HW disposal agent

Building T-827

One year

None specified. As per FGS-P Section C6.3.5.8, only provided to the HAAZ Commander upon request.

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

The AF environmental program adheres to the Environmental Management System (EMS) framework and its Plan, Do, Check, Act cycle for ensuring mission success. Executive Order (EO) 13693, Planning for Federal Sustainability in the Next Decade, U.S. Department of Defense Instruction (DoDI) 4715.17, Environmental Management Systems, AFI 32-7001, Environmental Management, and international standard, ISO 14001:2004, 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 managing associated risks, and installing a culture of continuous improvement. The HWMP serves as an administrative operational control that defines compliance-related activities and processes.

4.0 ROLES AND RESPONSIBILITIES

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

• Wing/Installation Commander

• ESOHC

• HW Manager/Alternate

• Shop/HW Generator Personnel

• Hazardous Waste Accumulation Point” (HWAP) and “Hazardous Waste Storage Area”

(HWSA) Supervisors/Managers

• Unit Commanders

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

• Contracting Officer

• Defense Logistics Agency Disposition Services

• Tenant Organizations

• AFCEC

Detailed information about typical responsibilities for these and other roles is available in AFI 32-7042, Waste Management, applicable installation supplements, and the HW Playbook. Additional HW management-related roles and responsibilities are described throughout this plan and in referenced documents.

Installation Supplement – Roles and Responsibilities

65th Air Base Group Commander (ESOHC Chair)

The 65 ABG Commander is ultimately responsible for HW management and compliance and will:

• Ensure all generating organizations, including tenant organizations, comply with the HWMP;

• Ensure all enforcement actions are resolved quickly.

Staff Judge Advocate (65 ABG/JA)

• Evaluates, reviews and ensures proper interpretation of Portuguese environmental laws, US Federal regulations, the Status of Forces Agreement and advises 65 CES/CEIE and the ESOHC as to the applicability of the laws and regulations;

• Advises Commanders of the potential liabilities associated with failure to comply with HW management regulations;

• Reviews all official inquiries from local authorities concerning the HW management program.

Public Affairs Office (65 ABG/PA)

• Acts as the focal point for inquiries from the news media and concerned citizens regarding HW and in the event of a HW incident or accident;

• Assists Incident Commander during situations involving HW incidents by keeping news media and the public aware of events;

• Assists 65 CES/CEIE in promoting the HW Management Program through the use of available information media.

Group Safety Office (65 ABG/SE)

• Assists all functional managers in ensuring that their working environment, work methods, and equipment meet the established standards for the protection of personnel and facilities in respect to the HW management program;

Base Civil Engineer (65 CES/CC)

• Has overall management responsibility of the Lajes environmental program and ensures that installation environmental office has adequate resources to effectively manage HW at Lajes.

Environmental Office (65 CES/CEIE)

• Assumes overall management of the HW program and reports status to the ESOHC;

• Reviews the HWMP annually, unless required more frequently, and proposes revisions as appropriate to keep the plan current;

• Oversees management of the HWSA, Building T-827;

• Develops, maintains, and coordinates the installation’s HW stream inventory;

• Implements procedures to ensure generators maintain up-to-date waste stream information and profiles, to include sustainment of the EESOH-MIS;

• Evaluates industrial processes to properly characterize the installation’s HW streams (to include used oil);

• Ensures HW initial and refresher training is provided annually to all personnel whose work involves HW;

• Liaises with the DLA-DS in implementing program regulations and policies, preparing necessary reports for installation activities, and managing disposal costs;

• Certifies HW turn-in documents (DD 1348-1A) and transportation manifests;

• Supports HW generators (workcenters) in the preparation of HWPS;

• Performs annual HW management compliance assessments and surveys;

• Maintains routine liaison with HQ United States Air Forces in Europe (USAFE), AFCEC/CFEE, Group Legal Office and Public Affairs in regard to HW inspections, assessments, regulatory interpretation and problem resolution;

• Track HW using EESOH-MIS;

• Provides technical expertise to generating activities regarding waste management, waste characterization, (i.e. identification, description and quantification), accumulation; storage, marking and labeling, minimization, recycling turn-in procedures and disposal;

• Interprets all analytical results and advises generators and waste managers of waste characteristics;

• Ensures funding requirements are properly identified and reported to AFCEC/CFEE;

• Coordinates and approves/disapproves of siting and design of HWAPs and HWSAs under the jurisdiction of the 65 ABG IAW applicable environmental standards;

• Signs waste registers generated by HWSA Manager.

Base Fire Department (65 CES/CEF)

• Provides emergency response and spill containment for HW spills as required;

• Coordinates and approves/disapproves of siting and design of HWAPs and HWSAs under the jurisdiction of the 65 ABG IAW applicable fire standards.

Bioenvironmental Engineering (86 AMDS/SGPB)

Bioenvironmental Engineering (BEE) functions are managed by the 86 AW at Ramstein Air Force Base, DSN 314-479-2220/2234. BEE accomplishes periodic visits to Lajes Field to provide general oversight.

• Provides, or arranges for, HW safety and health training (as specified in Section C6.3.9.3.4.3 of FGS-P) to Air Force employees and identifies worker requirements for use of personal protective equipment;

• Provides monitoring/oversight of base Hazardous Communication (HAZCOM) program;

• Provides Occupational and Environmental Health consultation services as outlined in AFI 48-

145, Occupational and Environmental Health Program;

• Advises HW Manager on completion of the health portions of the HWPS, on request.

Defense Logistics Agency—Disposition Services (DLA-DS)

• Provides copies of HW documentation to include (but not limited to) manifests, weight slips, delivery orders, annual reports and TIDs to 65 CES/CEIE for end-of-year reporting requirements;

• Provides information and guidance on completion of HWPSs;

• Verifies accuracy of HW weights prior to acceptance and completion of disposal actions;

• Reviews and verifies HWPS and manifests prior to acceptance and completion of disposal actions.

Contracting (65 CONF)

• Reviews all HW-related contracts to verify provisions are made IAW Federal Acquisition Regulations;

• Provides timely and effective contracting support to accomplish HW management incorporating FAR and other environmental policies and procedures.

Logistics Readiness Squadron-HAZMART (65 LRS/LGRMSH)

• Acts as the central point of hazardous material distribution, tracking, reuse and management;

• Attempts to reutilize excess HM and organizes shelf-life extensions to expired HM where possible;

• If unable to reutilize HM, creates Transfer Documents and requests Disposition in the Enterprise

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

Commanders of Generating Activities

Each Commander is ultimately responsible for HW management and compliance for HW generated by their unit and will:

• Ensure proper management of HW generated by their units;

• Appoint in writing to 65 CES/CEIE a primary and alternate manager for each HWAP (see

Appendix C – Sample Forms);

• Ensure all personnel with HW duties receive required initial and annual refresher training before assuming such duties, or work under the direct supervision of someone trained in those duties until training is successfully completed;

• Provide safe equipment and locations for HWAPs and ensure that the HWAPs are approved by

65 CES/CEIE & 65 CES/CEF;

• Allow assessment/inspection of HW facilities, shops, and equipment for HW management and regulatory compliance by authorized assessors/inspectors;

• Provide for the storage of, and budget for, emergency spill response equipment and supplies for

HW.

Hazardous Waste Accumulation Point Managers and Alternates

The HWAP Manager and Alternate assume overall responsibility for management of the HWAP. All generators of HW must be capable of recognizing, tracking and maintaining all documentation necessary for proper HW management. The Managers and Alternates main duties include:

• Successful completion of annual HWAP Manager training given by 65 CES/CEIE prior to working unsupervised with HW;

• Annual training of all individuals in their activity that generate, handle, store, or have the potential to be exposed to HW and maintaining documentation of the training for three years after that person has relinquished their HW duties;

• Coordinate with 65 CES/CEIE & 65 CES/CEF on initial location or relocation of HWAPs;

• Ensure proper management of the HWAP in accordance with the HWAP operation procedures found in Section 7.5;

• Ensure proper container management in accordance with Section 7.3;

• Maintain a HWAP Continuity Binder in accordance with Section 6.0;

• Submit requests to 65 CES/CEIE to ensure all wastes are properly evaluated to determine proper characterization for disposal;

• Notify 65 CES/CEIE when a change in type or quantity of HW generated will occur to ensure contract requirements for disposal can be processed in a timely manner;

• Minimize generation of HW through prudent management of hazardous materials under their control;

• For new waste streams, support waste generator with preparing HWPS;

• For recurring waste streams, verify received waste with existing HWPS;

• Comply with all other applicable provisions of this HWMP.

Hazardous Waste Storage Area Manager and Alternate (DLA-DS Contractor)

• Maintains HWSA, Facility T-827, in compliance with FGS-P and DLA-DS contractual requirements;

• Receives and stores of 65 ABG generated HW IAW FGS-P;

• Maintains a supply of appropriate empty containers that are uniquely identified for collection of HW marked, labeled and ready for delivery to the HWAP IAW the current HWPS;

• Assures all empty drums are marked with the word “EMPTY” and have all previous markings removed;

• Issues containers to HWAPs that are ready to receive HW. Creates the proper HW and class labels and places them on the container prior to issue to HWAP;

• Receives requests from the HWAP Manager to pick up full containers and transports the full containers from the work centers to the HWSA;

• Process full containers at the HWSA, including inspection of container and label information, annotate “full dates” on containers, track container weights and numbers;

• Identify Proper Shipping Name, Hazard Class, United Nations (UN) number and Packaging Class for all HW streams to be transported off-site;

• Assure that all usable hazardous materials are processed through LRS HAZMART before being accepted for disposal;

• Supply over pack drums and spill cleanup material to 65 ABG organizations (by CEIE request only);

• Receives requests and picks-up empty containers that once stored HW and, if serviceable, stores for reuse. If not serviceable, crushes and disposes as HW;

• Receives requests and picks-up empty aerosol cans. Punctures and crushes empty aerosol cans for disposal as HW;

• Picks up used small batteries collected at commissary and post office;

• Collects waste samples and develops waste profile sheets. Refer to the Waste Analysis Plan

(WAP) found in Appendix A for additional details;

• Maintains all HWSA records. Refer to Section 6 for additional details;

• Inspects the HWSA. Refer to Section 7.8 for additional details;

• Completes waste registers set forth in Appendix C7.A1, Chapter 7 of the FGS-P and provides to

65 CES/CEIE for signature;

• Sends monthly reports of HW received from the HWAPs to 65 CES/CEIE HW Program

Manager.

5.0 TRAINING

HW awareness training is provided to satisfy AFI 32-7042 and country-specific FGS requirements and needs. All personnel whose work involves HW, and their immediate supervisors, must successfully complete HW training appropriate to their job responsibilities. Until the employee has received the appropriate HW training, the employee may only handle HW under the supervision of a trained individual. HW training is provided by authorized personnel. Training records are maintained IAW the Recordkeeping and Reporting section of this plan. Installations will enter procedures regarding site-specific training requirements below based upon FGS and Host Nation (HN) regulations, consistent with the training matrix available through eDASH.

Installation Supplement – Training

65 CES/CEIE Hazardous Waste Program Manager Training

The 65 CES/CEIE Hazardous Waste Program Manager should receive initial HW training by completing the Air Force Institute of Technology (AFIT) Hazardous Waste Management Course WENV 521.

Annual refresher training requirements can be satisfied by conducting the HWAP Manager training or attending USAFE HW refresher training events hosted by AFCEC/CFEE.

HWSA Manager Training

The Lajes HWSA Managers (both Primary and Alternate POCs) are contractors hired by DLA-DS and, per contractual requirements, are responsible for obtaining any necessary HW training. The HWSA Managers may choose to attend the HWAP Manager training offered by the 65 CES/CEIE Hazardous Waste Program Manager as a means of receiving training on all topics required to meet DoD and FGS-P requirements. However, the responsibility to be fully trained and capable to work as HWSA Managers ultimately resides upon the contractor.

HWAP Manager Training

The HWAP Manager training is a classroom session conducted by the 65 CES/CEIE Hazardous Waste Program Manager covering all topics required to meet DoD and FGS-P requirements and Lajes-specific issues. The 65 CES/CEIE Hazardous Waste Program Manager will offer initial HWAP Manager training when new HWAP Managers are assigned those duties. Refresher training will be provided annually by the 65 CES/CEIE Hazardous Waste Program Manager.

Shop-Level HW Training

The shop-level HW training is a classroom and hands-on session conducted by each HWAP Manager for all employees in their shop who work with HW. A template for shop-level HW training is maintained by the 65 CES/CEIE Hazardous Waste Program Manager and covers all topics required to meet DoD and FGS-P requirements and Lajes-specific issues. The 65 CES/CEIE Hazardous Waste Program Manager will individually work with each HWAP Manager to update the template with shop-specific information.

The HWAP Manager will provide initial shop-level HW training prior to individuals in their shop working with HW and will then ensure that all shop personnel are provided the shop-level HW training annually thereafter.

6.0 RECORDKEEPING AND REPORTING

Recordkeeping

The installation complies with the following HW recordkeeping requirements as applicable based on generator status.

Summary of HW Recordkeeping Requirements

Record Retention Time Citation HW determination documentation

3 years from the closure of the HWSA and

HWAP

FGS

HW manifest (turn-in document)

3 years for incoming HW and 5 years for HW transported off-site

FGS

HWSA logs Until closure of installation FGS Hazardous waste inspection logs

3 years FGS

Employee HW training records

3 years from date of termination of duties FGS

Reporting

The HW 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 (EASI) database.

Installation Supplement – Record keeping and Reporting

Record Keeping

Hazardous Waste Accumulation Point Continuity Binder

Each Lajes HWAP will maintain a hard copy or electronic Continuity Binder with the documentation specified below at the following tabs:

• TAB 1 – HWAP Manager Appointment Letter o Must be signed by the generating unit’s Squadron Commander;

o See Appendix C – Sample Forms for template.

• TAB 2 -- HWAP Authorization Memorandum o Must be approved by 65 CES/CEIE and 65 CES/CEF;

o See Appendix C – Sample Forms for template.

• TAB 3 – Hazardous Waste Training Records o HWAP Manager training certificates’ o Shop personnel training records to include name and the dates it was received;

o Must be kept for current employees as long as they work at the installation and for an additional three years after the date they leave the base (or stop working at a position related to HW management).

• TAB 4 – HWAP Monthly Inspections o Monthly HWAP Manager inspections will be filed here and reviewed by 65 CES/CEIE

Hazardous Waste Program Manager during annual oversight inspection;

o 65 CES/CEIE Hazardous Waste Program Manager will provide results from the annual oversight HWAP inspection;

o Keep the twelve most recent monthly inspection forms on file until reviewed by 65

CES/CEIE Hazardous Waste Program Manager during annual oversight inspection o See Appendix C – Sample Forms for template.

• TAB 5 – Copy of FGS-P Hazardous Waste Chapter 6 o In place of a printed copy, HWAP may instead include a web link to the document on the 65

CES/CEIE eDASH web page.

• TAB 6 – Copy of Lajes HWMP o In place of a printed copy, HWAP may instead include a web link to the document on the 65 CES/CEIE eDASH web page.

• TAB 7 – Hazardous Waste Profile Sheets and/or Safety Data Sheets (SDS) for HW generated at the site;

o HWPS are generated in EESOH-MIS;

o 65 CES/CEIE Hazardous Waste Program Manager can provide assistance obtaining these.

• TAB 8 – Log of Wastes Turned In to the HWSA o A log must be kept of all HW turned in to the HWSA and the log must record the following information:

Drum Number (assigned by HWSA);

Waste Description;

Waste Steam Profile Number;

Container type and size;

Date container storage limit was reached or date pickup was requested (whichever came first);

Date of transfer to the HWSA;

HWAP Manager Signature;

HWSA Manager Signature;

o Log must be maintained for 3 years;

o See Appendix C – Sample Forms for template.

• TAB 9 – Site Specific Spill Plan o Can be obtained from the Lajes Spill Prevention and Response Plan (SPRP);

o 65 CES/CEIE Hazardous Waste Program Manager can provide assistance obtaining this.

Hazardous Waste Storage Area Records

The following records must be maintained by the HWSA Manager, to include all wastes received from HWAPs:

• Training Records for HWSA personnel;

o Must be kept for current employees as long as they work at the installation and for an additional three years after the date they leave the base (or stop working at a position related to HW management).

• Hazardous Waste Profile Sheets and Waste Analysis/Characterization Records;

o Must be retained until three years after closure of the HWSA.

• Manifests;

o Manifests of incoming HW must be retained for a period of 3 years;

o Manifests of HW that are transported off-site must be retained for 5 years.

• HWSA Weekly Inspection Logs;

o Records of inspections shall be maintained for a period of 3 years;

o Deficiencies and corrections shall be noted on the inspection log form;

o Deficiencies or problems discovered by the inspection shall be corrected immediately by the

HWSA Manager.

• HWSA Equipment Inspection Log;

o See Appendix C – Sample Forms for template;

o Records of inspections shall be maintained for a period of 3 years.

• Hazardous Waste Log;

o A written log will be maintained to record all HW handled and should consist of the following:

Name/address of generator;

Description and hazard class of the HW;

Number and types of containers;

Quantity of HW;

Date stored;

Storage location;

Disposition data to include: dates received, sealed, transported, and transporter used;

o The HW Log will be available to emergency personnel in the event of a fire or spill;

o Log will be maintained until closure or transfer of the installation.

• Hazardous Waste Tracking System (electronic).

o EESOH-MIS is the standardized Air Force HW tracking & reporting system. EESOH-MIS functions will be maintained to provide for:

Real time tracking of every container issued by the HWSA;

Site lists, waste stream lists, site personnel lists, training records and waste codes;

Production of reports of HW and waste oil processed through the HWSA, by organization, quantity, and type.

Training Documentation

Proper documentation is essential to an effective training program. Training records must be kept to provide evidence that the training was successfully completed; these records must be available for internal, as well as external, inspections. Training records for HWAP Managers and shop personnel are kept in TAB 3 of each HWAP Continuity Binder and training records for HWSA personnel are kept at the HWSA. Additionally, the 65 CES/CEIE Hazardous Waste Program Manager maintains a spreadsheet tracking the appointment of HWAP Managers and their most recent training completion dates. Training records for the 65 CES/CEIE Hazardous Waste Program Manager must be kept in the 65 CES/CEIE Environmental Office files. Training records must be kept for current employees as long as they work at the installation and for an additional three years after the date they leave the base (or stop working at a position related to HW management).

Reporting

Spill Reporting

65 ABG procedures, as outlined in the Spill Prevention and Response Plan, require responsible organizations to report releases of greater than 10 gallons of POL or any amount of HW releases requiring assistance of the Fire Department or the 65 CES Fuels Spill Response Team (65 CES/FSRT) to the 65 CES/CEIE Spill Program Manager at extension 535-6558 or cell 966183277.

7.0 PROCEDURES

This section contains procedures for managing HW from identification, accumulation, offsite transportation and disposal. The HW 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; select “Hazardous Waste” to generate the Waste Site Waste Stream Summary Report

Installation Supplement – Waste Inventory

The HWSA Manager or 65 CES/CEIE Hazardous Waste Program Manager should be contacted in the event that a current waste inventory for Lajes Field is needed and they will then generate a current report from EESOH-MIS using the steps outlined above.

7.2 Waste Identification

The HW 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 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

Refer to the WAP found in Appendix A for Lajes-specific waste identification procedures.

7.3 Container Management

Container management procedures are as follows:

• Containers storing HW must be in good condition and meet permit, 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.

• Containers with a residue of the contents on the exterior or the container should be considered leaking and contents transferred to another container, over packed, or cleaned if cleaning the residue is acceptable.

• 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.

• 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

HWAP Managers may obtain the appropriate empty containers from the HWSA. It is the ultimate responsibility of the HWAP and HWSA Managers to ensure the HW containers are managed according to the requirements described in Section 7.3, Container Management.

The following precautions should be taken at Lajes HWAPs and the HWSA to prevent container ruptures and leaks:

• Containers must not be overfilled; fill to 90% of capacity.

• Closed head containers must be filled using a funnel.

• Drums must not be stacked more than two high. Drums containing flammable liquids must not be stacked.

• Containers should be stored in an area, which is away from or protected from damage due to the movement of vehicles such as trucks, forklifts, etc.

• Drums and other containers must be handled and transported with equipment designed for the task. Drum grappler attachments may be purchased for tow motors to securely grab and move containers. Secure containers to pallets before moving pallets. Use drum carts designed for the types of containers used by your organization to reduce the likelihood of dropping a container during handling. Never balance drums on the forks of a forklift or tow motor.

Secondary Containment

As a best management practice, the Lajes HWAPs and HWSA store all HW containers in enclosed storage areas with built-in secondary containment. Hazardous waste containers at Lajes are NOT stored outside and affected by precipitation. Secondary containment systems within enclosed storage areas must be kept free of debris and must have sufficient capacity to contain 10% of the volume of stored containers or the volume of the largest container, whichever is greater.

7.4. Labeling and Marking

Containers used for the accumulation and transportation of HW must be properly identified with a Hazardous Waste marker and an appropriate hazard class label (flammable, corrosive, etc.) at all times from the start of accumulation to ultimate disposal IAW applicable laws and regulations. The Hazardous Waste marker will include a description of the contents of the container in the form of a Proper Shipping Name (PSN) as established in the waste characterization process and used on the waste manifest which accompanies the container to the ultimate disposal site.

When transporting HW via commercial transportation on public roads and highways, HW generators will prepare off-installation HW shipments in compliance with DoD Component Policies. Requirements may include placarding, marking, containerization, and labeling. HW designated for international transport will be prepared in accordance with the documents listed above and applicable international regulations.

EESOH-MIS, Hazardous Waste Module has a version of the HW label that can be customized (i.e., HN language) and utilized.

Installation Supplement – Labeling and Marking

At Lajes the HWSA personnel label, prior to being delivered to the HWA, all empty containers that will hold HW. The HWSA personnel ensure that the empty container is delivered with hazard class labels of the waste it will contain (i.e., flammable, corrosive, etc.) as well as a label with a “Hazardous Waste” marking. The “Hazardous Waste” marking label generated by the HWSA also contains additional information regarding the generator, waste and container. The HW label template to be used at Lajes is found in Appendix C – Sample Forms.

It is the HWAP Manager’s responsibility to ensure that the HW label remains legible and attached to the HW container as it is filled. If the label is damaged, the HWAP Manager must contact the HWSA Manager for a replacement label.

After a full HW container is transported by HWSA personnel to the HWSA, the container will be weighed and information will be entered into the Air Force waste tracking system, the EESOH-MIS HW module. At that time, additional information such as the container weight and the EESOH-MIS container ID# will be added to the label or a new label with this information will be printed.

7.5 Hazardous Waste Management

A HWAP may be used to accumulate no more than 208 liters (55 gallons) of hazardous waste, or 1 liter (1 quart) of acute hazardous waste, from each waste stream. When these limits have been reached, the generator will make arrangements within five working days to move the HW to a HWSA or ship it off-site for treatment or disposal.

Hazardous waste should not be stored longer than one year in a HWSA.

Wastes intended to be recycled or used for energy recovery (for example, used oil or antifreeze) are exempt from the 208-liter (55-gallons)/1-liter (1-quart) volume accumulation limits, but must be transported off-site to a final destination facility within one year.

Installation Supplement – Hazardous Waste Management

Hazardous Waste is temporarily stored at Lajes Field at facilities within the following two classifications:

HWAPs and the centralized HWSA. Hazardous Waste may only be accumulated and temporarily stored at the pre-designated HW sites listed in Appendix B – Hazardous Waste Locations. Procedures for properly establishing an HWAP are outlined below.

Hazardous Waste Accumulation Point Authorization

If a work center at Lajes Field desires to either create a new HWAP or move an existing HWAP, the POC for the HW site should complete and forward a request letter to the 65 CES/CEIE Hazardous Waste Program Manager. Once the request has been validated by 65 CES/CEIE, the memorandum will be coordinated through 65 CES/CEF for formal approval and authorization. A template HWAP Authorization Memorandum is included in Appendix C – Sample Forms.

Hazardous Waste Accumulation Point Managers Appointment

Each waste-generating work center shall appoint a primary and alternate site manager for each HWAP. A template HWAP Manager Appointment Memorandum is included in Appendix C – Sample Forms.

Hazardous Waste Accumulation Point Operating Procedures

The HWAP Manager and Alternate assume overall responsibility for management of the HWAP. Details on the overall management of the HWAP are outlined in section 4.0, Roles and Responsibilities of the HWAP Manager and Alternate.

The previously discussed waste identification (Section 7.2), container management and containment requirements (Section 7.3) and labeling and marking (Section 7.4) also apply to HWAP operations.

Furthermore, there are additional record keeping and reporting requirements (Section 6.0) relevant to HWAP operations also previously discussed. Other specific requirements for HWAPs are listed below:

• The HWAP must be at or near the point of generation and under the control of the operator.

• The HWAP must be designed and operated to provide appropriate segregation for different waste streams, including those that are chemically incompatible;

• Each HWAP is required to have a portable fire extinguisher and an emergency eye wash station, personal protective equipment, and a spill kit with adequate materials for the type of HW stored;

• Each HWAP will have warning signs appropriate for the waste being accumulated at that site to include a “No Smoking within 50 feet” and a “HWAP sign” posted at the site location;

o The HWAP sign will give the name and phone number for the Accumulation Point manager and emergency contact information;

o 65 CES/CEIE Hazardous Waste Program Manager will provide assistance in obtaining the appropriate signs.

• The HWAP Manager submits requests to the HWSA Manager via telephone at DSN 535-2448 or

COMM 295-57-2448 to pick up full containers and should typically expect containers to be collected within three working days. The HWSA Manager will replace the full containers with empty containers that are labeled to accept the same waste as the full container.

• When the full container is picked up, the HWAP Manager and HWSA Manager will both sign the HWAP Log of Wastes turned in to the HWSA and the HWAP Manager will keep this log in the continuity binder. See Appendix C – Sample Forms for the waste log template.

Hazardous Waste Storage Area Operating Procedures

There is only one authorized HWSA at Lajes Field, located at building T-827. The HWSA is operated by a DLA-DS contractor under the authority of 65 CES/CEIE. It is a temporary holding facility where the HW from the various HWAPs is centrally stored once the HWAPs arrive at their storage capacity. Two ISO tanks with a capacity of 23,000 liters each are located in the HWSA yard and are used to store bulk liquid wastes and subsequently transport them off site for disposal. The HW is stored at the storage area until removal is coordinated through DLA-DS and the waste is transported off site for disposal.

The previously discussed waste identification (Section 7.2), container management requirements (Section 7.3) and labeling and marking (Section 7.4) all apply to HWSA operations as well as recording keeping requirements (Section 6.0). There are other more rigorous requirements for HWSAs as listed below:

• Security:

The HWSA Manager must prevent the unknowing entry, and minimize the possibility for unauthorized entry, of persons or livestock onto the HWSA grounds. To meet this requirement, the Lajes HWSA has a gated fence around its perimeter. HWSA personnel must ensure the fence is in good repair and the gates are locked when not in use.

• Required signs:

o A sign with the legend "Danger, Unauthorized Personnel Keep Out" (“Perigo Proibida a

Entrada a Pessoal Não Autorizado”) must be posted at each entrance to the HWSA, and at other locations, in sufficient numbers to be seen from any approach to the HWSA; The legend must be written in English and Portuguese and must be legible from a distance of at least 7.62 meters (25 feet).

o "No Smoking" signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste. The sign must be in English and Portuguese.

o Fire safety equipment signs (square or rectangular, consisting of a white pictogram on a red background) must be posted at the HWSA.

• Required aisle space:

o Aisle space must allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation in an emergency;

o Containers must not obstruct an exit.

• Access to communications or alarm system:

o Whenever HW is being poured, mixed, or otherwise handled, all HWSA personnel involved in the operation have immediate access to an internal alarm (i.e., fire alarm activation switches) and emergency communication devices (i.e., telephones in the office area). The fire alarm system provides immediate emergency signal to HWSA personnel. Fire alarm sounds shall differ in quality and tone from any other on-site acoustical device and shall be provided with an independent energy supply.

o If there is only one person on duty at the HWSA premises, that person must have immediate access to a device, such as a telephone (immediately available at the scene of operation) or a hand held two way radio, capable of summoning external emergency assistance;

• Required equipment:

o Portable fire extinguishers, fire control equipment appropriate to the material in storage

(including special extinguishing equipment as needed, such as that using foam, inert gas, or dry chemicals), spill control equipment, and decontamination equipment;

o Water at adequate volume and pressure to supply water hoses, streams, foam producing equipment, automatic sprinklers, or water spray systems. An adequate number of personnel trained in the use of this equipment shall be present during normal working hours;

o Readily available personal protective equipment appropriate to the materials stored;

o Eyewash and emergency showers;

• Storage Practices:

o The storage of ignitable, reactive, or incompatible wastes must not threaten human health or the environment. Dangers resulting from improper storage of incompatible wastes include generation of extreme heat, fire, explosion and generation of toxic gases;

o The HWSA manager must take precautions to prevent accidental ignition or reaction of ignitable or reactive waste. This waste must be separated and protected from sources of ignition or reaction. While ignitable or reactive waste is being handled, the HWSA personnel must confine smoking and open flame to specially designated locations;

o Water reactive waste cannot be stored in the same area as flammable and combustible liquids.

Hazardous Waste Storage Area Closure Plan

A closure plan, dated December 2006, has been developed for the Lajes Field HWSA. The closure plan is maintained in the 65 CES/CEIE filing system and will be implemented in the future if a decision is ever made to close the HWSA at Building T-827.

7.6 Transportation

The HW Manager has overall responsibility for the transportation of HW from a HWAP to a HWSA, and from a HWSA to the disposal facility. The HW Manager ensures:

• All transportation over HN public roads is conducted IAW applicable HN or international transportation regulations.

• Containers are approved.

• Transporters have the appropriate training.

• Uniform Hazardous Waste Manifest are prepared for offsite transportation.

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

Installation Supplement – Transportation

On-base Transportation of HW

HW generated from Lajes Field HWAPs is picked up and transported by HWSA personnel.

Off-base Transportation to Final Disposal

• All off-base transportation of HW must be conducted by a company that holds a permit from the competent Portuguese authority.

• Off-base transportation of HW via surface modes must be in compliance with USAFE Instruction (USAFEI) 23-104, USAFE Command Dangerous Goods Program, with other regulations including local environmental laws and the technical provisions of the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR).

• If a waste final destination is mainland Portugal, the transport unit must comply with the provisions of the IMDG code for the sea portion and also for the mainland road portion with “Portaria 335/97 de 16 de Maio”.

All HW leaving Lajes Field will be accompanied by a manifest to ensure a complete audit trail from point of origin to ultimate disposal. This manifest will include:

• Generator's name, address, fax and telephone number;

• Generator’s unique identification number;

• Transporter's name, address, fax and telephone number;

• Destination name, address, fax and telephone number;

• Description of waste (Waste designation, Waste code, Physical form and Container type, material and number);

• Total quantity of waste;

• Date of shipment;

• Date of receipt.

The waste generator (65 CES/CEIE Hazardous Waste Program Manager) will:

• Complete section 1 of the 3-copy waste manifest;

• Verify that the waste transporter completes section 2 of the manifest;

• Provide 2 copies of the waste manifest to the waste transporter and retain one copy.

The waste transporter will:

• Complete section 2 of the 3-copy waste manifest;

• Carry two copies of the waste manifest during transport;

• Verify that the receiver of the waste manifest completes section 3 of the two copies;

• Provide a copy of the waste manifest to the waste receiver and retain one.

Tank vehicles transporting used oils shall be clearly and legibly labeled with the phrase “Used oil transportation” (“Transporte de óleos usados”). An SDS shall be carried in the driver’s cab during all loading, transportation and unloading of used oil.

7.7 Turn In/Disposal

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

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

Installation Supplement – Turn In/Disposal

Generating activities will provide identification of incoming waste on the HWPS to the HWSA Manager. Prior to accepting the waste, the HWSA Manager will:

• Inspect the waste to ensure it matches the description provided on the container label and

HWPS;

• Ensure that no waste is accepted for storage unless a HWPS is provided, or available and properly referenced;

• Request a new HWPS from the HWAP Manager if there is reason to believe that the process generating the waste has changed;

• Analyze waste shipments in accordance with the waste analysis plan to determine whether it matches the waste description on the accompanying manifest and documents;

• Reject shipments that do not match the accompanying waste descriptions unless the generator provides an accurate description.

7.8 Inspection

Inspection processes fulfill the “Check” function of the EMS “Plan, Do, Check, Act” cycle. HWSA are inspected routinely IAW Chapter 6 of the FGS to ensure proper accumulation and container management.

All other inspections occur IAW AFI 90-201, The Air Force Inspection…