Attachment 14_JBER Hazardous Waste Management Plan - 2024.pdf

Hazardous Waste Management

Plan

Joint Base Elmendorf-Richardson

February 9, 2024

United States Air Force

673 Civil Engineer Squadron/Environmental Compliance

724 Quartermaster Road

Joint Base Elmendorf-Richardson, Alaska 99505

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Hazardous Waste Management Plan 1

Table of Contents

ABOUT THIS PLAN

DOCUMENT CONTROL

1 OVERVIEW AND SCOPE

2 INSTALLATION PROFILE

3 ENVIRONMENTAL MANAGEMENT SYSTEM

4 ROLES AND RESPONSIBILITIES

4.1 INSTALLATION SUPPLEMENT – GENERAL ROLES AND RESPONSIBILITIES

4.1.1 HAZARDOUS WASTE PROGRAM MANAGER

4.1.2 UNIVERSAL WASTE PROGRAM MANAGER

4.1.3 CENTRAL ACCUMULATION AREA OPERATORS

4.1.4 COMMANDERS/LEADERS OF GENERATING ACTIVITIES

4.1.5 UNIT ENVIRONMENTAL COORDINATORS

4.1.6 PRIMARY AND ALTERNATE HAZARDOUS WASTE MANAGERS

4.1.7 FACILITY MANAGERS

5 TRAINING

5.1 21

5.2 21

5.3 21

5.4 21

5.5 JBER-SPECIFIC TRAINING REQUIREMENTS FOR MILITARY, CIVILIAN, AND

CONTRACTOR PERSONNEL

5.5.1 TIMEFRAMES FOR COMPLETING INITIAL TRAINING

5.5.2 JBER-SPECIFIC TRAINING OPPORTUNITIES

5.5.2.1 JBER HAZARDOUS WASTE MANAGER COURSE

5.5.2.2 NON-CREDITABLE HAZARDOUS WASTE PHARMACEUTICAL

TRAINING 25

5.5.2.3 UNIVERSAL WASTE TRAINING

5.5.2.3.1 FACILITY MANAGERS

5.5.2.3.2 NON-DELEGATED UNIVERSAL WASTE POINTS-OF-CONTACT ... 25

5.5.2.4 ON-THE-JOB TRAINING

Hazardous Waste Management Plan 2

6 RECORDKEEPING AND REPORTING

7 PROCEDURES

7.1 WASTE INVENTORY

7.2 WASTE IDENTIFICATION

7.3 CONTAINER MANAGEMENT

7.4 LABELING AND MARKING

7.5 ACCUMLATION AREA MANAGEMENT

7.6 TRANSPORATATION

7.7 TURN IN/DISPOSAL

7.8 INSPECTION

7.8.1 INSPECTION

7.9 WASTE MINIMIZATION/HW RECYCLING

7.10 PREPAREDNESS AND PREVENTION

7.11 WASTE SPECIFIC PROCEDURES

8 REFERENCES

9 ACRONYMS

10 DEFINITIONS

11 INSTALLATION-SPECIFIC CONTENT

11.1 UNIVERSAL WASTE TYPES

11.2 RECORDKEEPING AND REPORTING

11.3 HAZARDOUS WASTE RECORDS

11.4 HAZARDOUS WASTE NOTEBOOKS

11.5 UNIVERSAL WASTE ACCUMULATION AREA NOTEBOOKS

11.6 WASTE STREAM INVENTORY

11.7 WASTE IDENTIFICATION AND WASTE ANALYSIS PLAN

11.8 JBER REQUIREMENTS FOR WASTE ACCUMULATION

11.8.1 WHAT MUST A PRIMARY OR ALTERNATE HAZARDOUS WASTE

MANAGER DO WHEN THE ORGANIZATION RECEIVES A CONTAINER FOR

HAZARDOUS WASTE?

11.8.2 WHAT MUST A PRIMARY OR ALTERNATE HAZARDOUS WASTE

MANAGER DO WHEN ACCUMULATING HAZARDOUS WASTE IN A SATELLITE

ACCUMULATION AREA?

Hazardous Waste Management Plan 3

11.8.3 WHAT MUST A PRIMARY OR ALTERNATE HAZARDOUS WASTE

MANAGER, FACILITY MANAGER, OR NON-DELEGATED UW POC DO WHEN

THE ORGANIZATION RECIEVES A CONTAINER FOR UNIVERSAL WASTE?

11.8.4 WHAT MUST A PRIMARY OR ALTERNATE HAZARDOUS WASTE

MANAGER DO WHEN THE ORGANIZATION HANDLES UNIVERSAL WASTE AT A

SATELLITE ACCUMULATION AREA?

11.8.5 WHAT MUST A FACILITY MANAGER OR NON-DELEGATED UW POC DO

WHEN THE ORGANIZATION HANDLES UNIVERSAL WASTE (UW MANAGED AT

THE UWAA ONLY)?

11.9 HAZARDOUS WASTE CENTER REQUIREMENTS

11.10 UNIVERSAL WASTE ACCUMULATION REQUIREMENTS

11.11 UNKNOWN WASTE AND LABELING

11.12 REQUIREMENTS APPLICABLE TO ALL ACCUMULATION AREAS

11.13 CONTAINER ISSUANCE AND PICKUP PROCEDURES

11.14 WASTE TRANSPORTATION AND DISPOSAL

11.15 HW MANIFESTS

11.16 INSPECTIONS

11.17 SPECIFIC WASTE STREAM REQUIREMENTS

11.17.1 CONTAMINATED RAGS AND ABSORBENTS

11.17.2 OIL AND FUEL FILTERS

11.17.3 PAINT BOOTH FILTERS

11.17.4 MUNITIONS

11.17.5 MIXED WASTE

11.17.6 AEROSOL CANS

11.17.7 FLUORESCENT LAMPS

11.17.8 USED OIL

11.17.9 BATTERIES

11.17.10 TONER CARTRIDGES

11.18 MANAGING REGULATED WASTE ON JBER DURING EXTENDED TRAINING

EXERCISES AND DEPLOYMENTS

11.19 REGULATED WASTE GENERATED BY CONTRACTORS ON JBER

12 REFERENCES

Waste Analysis Plan ...................................................................................................................... A

Hazardous Waste Streams/Profiles ................................................................................................. B

Hazardous Waste Management Plan 4

Hazardous Waste Training Plan...................................................................................................... C

Inspection Forms ............................................................................................................................ D

Base Map ........................................................................................................................................ E

Satellite Accumulation Area Sign ................................................................................................... F

HW Compatibility .......................................................................................................................... G

Appointment and Training of Primary and Alternate Hazardous Waste Managers ...................... H

Universal Waste Accumulation Management Sign ......................................................................... I

Used Oil Management ..................................................................................................................... J

Oil/Water Separator User Knowledge Statement .......................................................................... K

POL-Contaminated Soil User Knowledge Statement ..................................................................... L

Points of Contact ............................................................................................................................ M

Waste Container Certification Form .............................................................................................. N

Checklist for the First Person Observing a Spill ............................................................................ O

Acknowledgement of Understanding ............................................................................................. P

Used Oil Certification Statement ................................................................................................... Q

JBER Hazardous Waste Manager Course....................................................................................... R

JBER Spill Reporting Poster ........................................................................................................... S

Hazardous Waste Management Plan 5

ABOUT THIS PLAN

This installation-specific Environmental Management Plan (EMP) uses the U.S. Air Force’s

(AF) standardized Hazardous Waste Management (HWMP) template. This plan is not an inventory of all hazardous waste (HW) requirements and practices. Where applicable, external resources and associated document links, including Air Force Instructions (AFIs); Air Force

Manuals (AFMANs); AF Playbooks; and federal, state, local, and permit requirements, are referenced to ensure current content.

Each section of this plan begins with the standard language that addresses AF and Department of

Defense (DoD) policy and federal requirements. The standard language is restricted from editing to ensure consistent application across the AF enterprise. Standard language is maintained by the

Air Force Civil Engineer Center (AFCEC) designated Subject Matter Expert (SME) for this plan.

Immediately following the standard text are installation-specific sections that address state, local, and installation-specific requirements and processes. Installation sections are maintained and updated by the installation HW Program Manager and/or AFCEC Section appointed to support the section.

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

DOCUMENT CONTROL

Standardized HWMP Template

In accordance with (IAW) the AFCEC Environmental (CZ) Business Rule (BR) 08, EMP

Review, Update, and Maintenance, the standard content in this HWMP template is reviewed periodically, updated as appropriate, and approved by the HW SME.

This version of the template is current as of 10/03/2023 and supersedes the 2021 version.

NOTE: When installations update their HWMPs, installations should adopt the most recent version of this template available. Installations are not required to change HWMPs after template updates.

Installation HWMP

The initial HWMP must be approved and signed by the Installation Commander (at the time of publication) as the legal HW Generator for the Environmental Protection Agency (EPA) ID assigned to this installation. The approval can be via signature or as documented in appropriate

Environment, Safety, and Occupational Health Council (ESOHC) minutes (AFMAN 32-7002, 5.2.2.). NOTE: This is not a Wing Contingency Plan and is not governed by installation or Wing plans or readiness format or coordination requirements of DAFI 10-401, Operations Planning and Execution. It is governed by AFMAN 32-7002, Environmental Compliance and Pollution

Prevention, Section 5.2. Hazardous Waste Management Plan (HWMP). Because this is not a

Hazardous Waste Management Plan 6 contingency plan, coordination should be with EMS CFT and applicable units with roles and responsibilities in the HWMP. The plan does not require a new signature after each change in wing command.

Record of Updates – The HWMP is updated as changes to waste generation and management practices occur, including those driven by changes in applicable regulations and approved by the installation HW Program Manager as the plan Office of Primary Responsibility

(OPR). Formatting and administrative changes such as the incorporation of updated regulatory language, or other minor updates are documented below.

Record of Annual Review – IAW AFMAN 32-7002, this plan is reviewed annually by the EMS

CFT. Formatting and administrative changes should be noted in the previous paragraph for record of updates as approved by the EMS CFT Chair and do not require Installation

Commander or Environmental, Safety, and Occupational Health Council (ESOHC) approval. Substantive revisions require coordination and approval by the Installation

Commander as determined by the EMS CFT Chair and/or IAW host installation procedures. Substantive changes include manpower or resource requirements changes that impact installation hazardous waste generating organizations.

Hazardous Waste Management Plan 7

Record of Updates

Change No.

Nature of Change

Date of Change

Approved By

Change to accommodate

AFMAN 32-7002,

minor grammar, personnel changes, management of aerosol cans as universal waste, and waste accumulation in administrative facilities.

April 28, 2021

673 ABW/CC

Transfers HWMP to approved U.S. Air

Force template.

Defines universal waste roles and responsibilities for:

Universal Waste

Program Manager;

Waste Managers;

Facility Managers;

and non-delegated points-of-contact.

Defines training and inspection requirements. Defines universal waste container management processes. Updated

Hazardous Waste

Management Plan points-of-contact.

April 12, 2022

Environmental, Safety, and

Occupational Health

Council

Changes include removing the minimum rank requirement for

Alternate Hazardous

Waste Managers, eradicating verbiage specific to TSDF

Hazardous Waste Management Plan 8 operations, identifying the

Hazardous Waste

Program Manager as a key person with specific roles and responsibilities, reorganizing installation-specific training information, updating existing appendices and introducing two new appendices, and revising verbiage throughout the environmental management plan to create uniformity and clarity.

February 23, 2023

Environmental

Management System

Cross Function Team

Updated HWMP to be reflective of approved template language, added clarifying verbiage, and provided guidance for the appropriate management of regulated waste when participating in an extended training exercise or deployment.

Environmental

Management System

Cross Functional

Team

Hazardous Waste Management Plan 9

Record of EMS CFT Annual Review

Review Date

EMS CFT Chair

Notes/Remarks

March 23, 2022

Mr. Mike Schmidt

Hazardous Waste

Management Plan to be presented to Environmental, Safety, and Occupational

Health Council for approval.

February 23, 2023

Dr. Mark Prieksat

Minor Hazardous Waste

Management Plan revisions approved by the

Environmental Management

System Cross Functional

Team.

Dr. Mark Prieksat

Minor Hazardous Waste

Management Plan revisions approved by the

Environmental Management

System Cross Functional

Team.

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Hazardous Waste Management Plan 10

1 OVERVIEW AND SCOPE

This HWMP contains procedures for management of HW. In lieu of federal, or state requirements, AFMAN 32-7002, acts as the main driver for the HWMP. The HW Playbook serves as a supplemental guidance to this plan. Where applicable, DoD, AF, and Federal

Resource Conservation and Recovery Act (RCRA) requirements are included. Each installation must include supplements as warranted to address applicable State and/or local requirements/procedures.

Joint Base Elmendorf-Richardson (JBER) is a large quantity generator (LQG) of HW as defined by the Code of Federal Regulations (CFR), Title 40, Chapter 1, Subchapter I, Part 260, Subpart

B, Section 260.10. There are approximately 260 HW satellite accumulation areas (SAAs) regulated in accordance with 40 CFR § 262.15, and one or more central accumulation areas

(CAAs) regulated in accordance with 40 CFR § 262.17. In addition, there are hundreds of universal waste accumulation areas (UWAAs) as well as accumulation areas for regulated recyclables such as used oil and mixed fuels. Appendix E – Base Map, depicts SAA and CAA locations throughout JBER. The number of SAAs and CAAs will change as the type and volume of waste and material fluctuates due to JBER’s unique mission requirements. Current information about SAAs may be viewed in the Enterprise Environment, Safety and Occupational

Health – Management Information System (EESOH-MIS). JBER is responsible for all hazardous waste management activities that occur on JBER.

Each organization that generates waste in an industrial facility is required to have a Primary and

Alternate Hazardous Waste Manager, regardless of whether the organization knowingly generates waste or believes it will not generate hazardous or universal waste.

Commanders/leaders must appoint Primary and Alternate Hazardous Waste Managers in accordance with Appendix H – Appointment and Training of Primary and Alternate Hazardous

Waste Managers.

The Hazardous Waste Program Manager, within the 673d Civil Engineer

Squadron/Environmental Compliance Section (673 CES/CEIEC), is responsible for oversight and support of all hazardous waste management activities and has authority for interpreting requirements of this environmental management plan as well as all applicable regulations. The office of the Hazardous Waste Program Manager is located at 724 Quartermaster Road, as depicted within Appendix E – Base Map. Contact information for the Hazardous Waste Program

Manager and others located within Appendix M – Points of Contact.

The goals of JBER’s HW program are to:

▪ Protect all personnel on JBER;

▪ Comply with applicable instructions, statutes, and regulations;

▪ Support the JBER mission; and

▪ Reduce cost and risk when practicable.

Hazardous Waste Management Plan 11

2 INSTALLATION PROFILE

Table 2-1: Installation Profile.

Scope of Plan

This environmental management plan applies to all military, civilian, and contractor personnel working aboard JBER. All personnel, regardless of status (temporary or permanent) are required to comply with this environmental management plan.

OPR (Civil Engineer or other designated office)

673 CES/CEIEC has overall responsibility for implementing this environmental management plan and is the primary organization for monitoring compliance with applicable federal, state, and local regulations.

HW Program Manager

M. Alex Cierlitsky

673 CES/CEIEC

matthew.cierlitsky@us.af.mil

(907) 384-3322

Alternate HW Program Manager Vacant

Emergency Contacts

In the event of a spill, fire, or explosion involving hazardous waste, dial 911 and indicate the incident is on JBER. JBER-specific spill reporting procedures are outlined within Appendix S – JBER Spill

Response Poster. The first person to observe a spill will complete the checklist shown in

Appendix O – Checklist for the First Person

Observing a Spill. For additional contact information, please see Appendix M – Points of Contact.

Waste Registration Numbers EPA ID Number: AK8570028649

HW Generator Status Large quantity generator.

Universal Waste Handler Status Large quantity handler.

Permitted HW Operations

RCRA Hazardous Waste Management

Facility Permit

Effective Date: December 7, 2023

Expiration Date: October 29, 2033

The RCRA Hazardous Waste Management

Facility Permit addresses hazardous waste activities at SAAs, CAAs, solid waste management units (SWMUs), and a former open burn/open detonation pad.

Hazardous Waste Management Plan 12

Federal Regulatory References

40 CFR Parts 260-279

40 CFR Part 761

49 CFR Parts 171-185

State and Local Regulatory Agencies

The State of Alaska adopted by reference, the federal Hazardous Waste Regulations as outlined within Title 18 Alaska

Administrative Code (AAC), Chapter 62 –

Hazardous Waste (18 AAC § 62). Therefore, the Alaska Department of Environmental

Conservation (ADEC) does not have an EPA-authorized hazardous waste program.

State and Local Regulatory References 18 AAC § 62

DLA-DS area office and/or approved HW disposal contractors

The Defense Logistics Agency Disposition

Services (DLA-DS) Anchorage office provides local area support to JBER. Active

DLADS recycle and waste disposal contracts are listed below.

Hazardous Waste Service Contract

Contract Number: SP450020D0015

Active Dates: April 2020-April 2025

Contract managed by DLA-DS for the transportation and disposal of hazardous waste, universal waste, and non-hazardous waste.

Mixed Fuels Sales Contract

Contract Number: 4001199641

Effective Date: December 17, 2023

Expiration Date: December 16, 2026

Contract managed by DLA-DS for the transportation and recycling of mixed fuels.

Lead Acid Battery Sales Contract

Contract Number: 4001069774

Quantity: 375,000 Lbs.

Contract managed by DLA-DS for the transportation and recycling of used lead acid batteries.

HW Accumulation Sites

JBER operates one CAA located at Building

4314.

There is approximately 260 SAAs and hundreds of UWAAs throughout JBER.

Hazardous Waste Management Plan 13

Current SAA and UWAA information are maintained in EESOH-MIS.

HW Accumulation Time Limits

SAAs: Unlimited (as long as the volume of waste does not exceed the limits outlined within 40 CFR 262.15).

CAA: 90-calendar days.

HW Generator Reporting Frequencies

Biennial Report

The Biennial Report is due no later than

March 1 of each even-numbered year (every two years). This report covers waste activities that took place during the previous odd-numbered year (one year of data).

Annual Corrective Action Progress Report

The Annual Corrective Action Progress

Report is due in December of each year. This report covers environmental restoration and construction activities that took place during

January – December.

Hazardous Waste Management Plan 14

3 ENVIRONMENTAL MANAGEMENT SYSTEM

The DAF environmental program adheres to the Environmental Management System (EMS) framework and its "Plan, Do, Check, Act" cycle for ensuring mission success. Executive Order

(EO) 14057, Catalyzing Clean Energy Industries and Jobs Through Federal

Sustainability; DoDI 4715.17, Environmental Management Systems, DAFI 32-

7001, Environmental Management; and International Organization for Standardization (ISO)

14001 standard, Environmental Management Systems - Requirements with guidance for use, provide guidance on how environmental programs should be established, implemented, and maintained to operate under the EMS framework.

The HW management program employs EMS-based processes to achieve compliance with all legal obligations and current policy drivers, effectively manage associated risks, and instill a culture of continuous improvement. The HWMP serves as an administrative operational control that defines compliance-related activities and processes.

Environmental Action Plans (EAPs) are developed and maintained as part of the overall EMS on eDASH. EAPs are tools that translate environmental requirements and targets into actionable plans for the HWPM and responsible personnel. HW requirements should be incorporated in installation EAPs to record monitoring and conformance for inspections and audits.

Hazardous Waste Management Plan 15

4 ROLES AND RESPONSIBILITIES

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

▪ Wing/Installation Commander;

▪ ESOHC;

▪ HW Program Manager/Alternate(s);

▪ Shop/HW Generator Personnel;

▪ Satellite Accumulation Area (SAA) and Central Accumulation Area (CAA)

Supervisors/Managers;

▪ Unit Commanders;

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

▪ Contracting Officer;

▪ Defense Logistics Agency Disposition Services;

▪ Tenant organizations; and

▪ AFCEC.

Detailed information about typical responsibilities for these and other roles is available in AFM

32-7002, applicable installation supplements, and the HW Playbook. This plan implements these responsibilities for this installation. Additional HW management-related roles and responsibilities are described throughout this plan and in referenced documents.

4.1 INSTALLATION SUPPLEMENT – GENERAL ROLES AND

RESPONSIBILITIES

Numerous personnel throughout JBER work in support of this environmental program. These key personnel include the 673d Civil Engineer Squadron/Environmental Quality (673

CES/CEIE) section, Hazardous Waste Program Manager, Universal Waste Program Manager, CAA operators, commanders/leaders of generating activities, Unit Environmental Coordinators, Primary and Alternate Hazardous Waste Managers, and Facility Managers. The roles and responsibilities for each of these key personnel are identified below.

4.1.1 HAZARDOUS WASTE PROGRAM MANAGER

The Hazardous Waste Program Manager, within the 673d Civil Engineer

Squadron/Environmental Compliance (673 CES/CEIEC) section, is responsible for providing oversight and support for hazardous and other regulated waste management activities on JBER.

The office of the Hazardous Waste Program Manager is located at 724 Quartermaster Road, as depicted within Appendix E – Base Map. Contact information for the Hazardous Waste Program

Manager is located within Appendix M – Points of Contact and Table 2-1: Installation Profile.

Hazardous Waste Management Plan 16

The Hazardous Waste Program Manager:

▪ Oversees the centralized management of all HW generated on JBER;

▪ Ensures all hazardous and other regulated wastes generated on JBER are recycled or disposed of in accordance with local, state, and federal regulations;

▪ Updates the Hazardous Waste Management Plan and establishes specific waste management procedures;

▪ Interfaces with regulators, stakeholders, ESOHC members, Environmental Management

System Cross Functional Team (EMS-CFT) members, Hazardous Material Management

Plan (HMMP) Team members, environmental program managers, and generators;

▪ Tracks programming and execution of HW requirements; and

▪ Provides accurate information within environmental reports by safeguarding HW records.

4.1.2 UNIVERSAL WASTE PROGRAM MANAGER

The Universal Waste Program manager, within 673 CES/CEIEC, is responsible for providing oversight and support for all universal waste (UW) management activities on JBER. The office of the Universal Waste Program Manager is located at 724 Quartermaster Road, as depicted in within Appendix E – Base Map. Contact information for the Universal Waste Program Manager is located within Appendix M – Points of Contact. In addition to any specific compliance responsibilities that are specified throughout this environmental management plan, the Universal

Waste Program Manager:

▪ Issues UW containers with labels to UWAAs that are not located at an SAA;

▪ Tracks UW containers issued to UWAAs that are not located at an SAA;

▪ Provides UW one-on-one training, as necessary;

▪ Tracks UW training for Facility Managers and non-delegated UW points of contact

(POCs) receiving one-on-one training; and

▪ Delivers and picks up UW containers at UWAAs that are not located at an SAA.

4.1.3 CENTRAL ACCUMULATION AREA OPERATORS

The operator of the central accumulation area (CAA) (hereinafter referred to as the Hazardous

Waste Center) supports the Hazardous Waste Program Manager and:

▪ Ensures accumulation of waste in the CAA is in accordance with 40 CFR 262.17;

▪ Provides waste containers and container labels;

▪ Obtains waste samples and waste analysis;

▪ Inspects the CAA as required by 40 CFR 262.17;

▪ Tracks all waste containers and waste disposition in EESOH-MIS;

▪ Tracks UW containers and waste disposition in EESOH-MIS for UW containers issued to

SAAs only;

▪ Assists the Hazardous Waste Program Manager with data needs and data calls;

▪ Maintains an inventory of waste accumulated in the CAA;

Hazardous Waste Management Plan 17

▪ Delivers empty waste containers to organizations, and picks up waste containers from locations throughout JBER;

▪ Establishes and maintains waste profiles;

▪ Develops and submits waste turn-in documentation to ensure transportation of waste to permitted facilities, prior to exceeding the 90-day limit applicable to accumulation of waste in a CAA;

▪ Packages and labels waste for transportation in accordance with applicable federal regulations;

▪ Submits documentation to DLA-DS to ensure timely preparation of the biennial HW report;

▪ Inspects SAAs throughout JBER and communicates findings to the Hazardous Waste

Program Manager;

▪ Provides advice to waste generators on JBER;

▪ Assists the Hazardous Waste Program Manager with exception reporting and required documentation, when applicable;

▪ Provides HW training, UW training, and non-creditable HW pharmaceutical training to military and civilian personnel on JBER in accordance with federal regulations.

▪ Maintains required documentation which may include, but is not limited to, waste analysis, waste profiles, inspection documentation, Uniform Hazardous Waste Manifests, non-hazardous waste manifests, UW shipment records, bills of lading, shipping documentation, waste exception reporting, training records, and appointments of Primary and Alternate Hazardous Waste Managers.

4.1.4 COMMANDERS/LEADERS OF GENERATING ACTIVITIES

Commanders/leaders of generating activities will:

▪ Appoint UECs per Air Force Instruction (AFI) 32-7001 Environmental Management;

▪ Ensure that a Primary and Alternate Hazardous Waste Manager is formally appointed as outlined within Appendix H – Appointment and Training of Primary and Alternate

Hazardous Waste Managers. Allows facilities, shops, and equipment to be inspected for

HW management regulatory compliance by installation fire, safety and health personnel, Hazardous Waste Program manager, and authorized inspectors;

▪ Submit a written request to the Hazardous Waste Program Manager to establish an initial

SAA;

▪ Provide safe equipment and locations for SAAs and UWAAs;

▪ Identify funding requirements for HW equipment and allocates funds based upon regulatory requirements; and

▪ Require the management of SAAs to comply with federal HW management regulations and with this environmental management plan; and

▪ Ensure all personnel (including contractors) under your command who handle HW or who supervise the handling of HW have received required training, as outlined in the

Hazardous Waste Management Plan 18

Section 5.0 and Appendix H – Appointment and Training of Primary and Alternate

Hazardous Waste Managers.

4.1.5 UNIT ENVIRONMENTAL COORDINATORS

In accordance with AFI 32-7001 and FRAGORD 629 to OPORD09-009, UECs shall maintain the following responsibilities:

▪ Serve as the Environmental Management System (EMS) conduit between the environmental function and their unit;

▪ Attend UEC training as provided by the installation within 90-days of appointment;

▪ Manage and monitor the EMS requirements for the unit. Provide any information required for installation environmental and sustainability performance measures;

▪ Meet with new personnel and review the environmental risks and impacts associated with their duties. Ensure new personnel receive EMS training;

▪ Monitor State 1 Management Internal Control Toolset (MICT) Self-Assessment

Checklists (SACs) for all shops and ensure questions are answered accurately and up-to-date;

▪ Assist unit and environmental function with tracking and closing our environmental compliance findings, as required;

▪ Attend EMS Cross Functional Team (EMS-CFT) and other working groups, as requested;

and

▪ Ensure smooth transition of UEC responsibilities and appointments by maintaining a continuity binder and notifying the appointing commander of required replacement.

Additionally, it is highly encouraged that UECs disseminate environmental outreach materials provided by 673 CES/CEIEC to their units.

4.1.6 PRIMARY AND ALTERNATE HAZARDOUS WASTE MANAGERS

Waste managers are responsible for supporting the obligation of their organization commander/leader to comply with this environmental management plan and all HW regulations.

In addition to any specific compliance responsibilities that are specified throughout this environmental management plan, the Primary and Alternate Hazardous Waste Manager:

▪ Serves as the focal point for the organization’s HW management activities;

▪ Serves as the focal point for the organization’s UW management for UW managed at a

SAAs;

▪ Coordinates with the Hazardous Waste Center and Hazardous Waste Program Manager to ensure that existing and new waste streams are properly determined to be either hazardous or non-hazardous at the point of generation of the waste;

▪ Must be familiar with this environmental management plan.

▪ Attends the JBER Hazardous Waste Manager Course training as required by Appendix H

– Appointment and Training of Primary and Alternate Hazardous Waste Managers;

Hazardous Waste Management Plan 19

▪ Conducts routine inspections of each SAA and documents the inspection results utilizing the forms found within Appendix D – Inspections Forms. HW inspections must be completed at least once every 7-calendar days and UW inspections must be completed at least once every 30-calendar days;

▪ Trains other organization personnel, as described in this environmental management plan;

▪ Maintains documentation of all inspections and trainings and provides documentation of inspections and trainings upon a request made by JBER Environmental Compliance staff or regulatory agency personnel;

▪ Affixes signs at all SAAs, as described within Appendix F – Satellite Accumulation Area

Sign;

▪ Ensures that waste placed in containers only when waste is exactly as described on container labels,

▪ Remains aware that placement of waste not accurately described by container labels may be a violation of federal regulation;

▪ Ensures that waste generation, accumulation, pickup, and recordkeeping all comply with applicable policies, regulations, laws, and this environmental management plan,

▪ Coordinate with the Hazardous Waste Program Manager, Fire Prevention, Bioenvironmental Engineering, and applicable Safety office during the placement (or relocation) of a SAA,

▪ Notifies the Hazardous Waste Program Manager of all changes in activities including, but not limited to, the location of a new SAA, relocation of an existing SAA, any change in chemicals used in an existing waste generation process, generation of a new waste stream, and any change in waste managers,

▪ Ensures the organization commander/leader is aware of a change that will require appointment of a replacement Primary or Alternate Hazardous Waste Manager in accordance with Appendix H – Appointment and Training of Primary and Alternate

Hazardous Waste Managers.

▪ Corrects deficiencies to ensure compliance with HW regulations and this environmental management plan,

▪ Provides completed and signed waste container certification forms and user knowledge statements as required by this environmental management plan; and

▪ Contacts the Hazardous Waste Center or the Hazardous Waste Program Manager when he/she has a question about waste management or desires compliance assistance.

4.1.7 FACILITY MANAGERS

Facility managers are responsible for supporting the obligation of their organization commander/leader to comply with all UW regulations as well as this environmental management plan. In addition to any specific compliance responsibilities that are specified throughout this environmental management plan, a Facility Manager:

Hazardous Waste Management Plan 20

▪ Serves as the focal point for the organization’s UW management activities only if the

UW is not being managed at an SAA;

▪ Coordinates with the Universal Waste Program Manager to establish a new UWAAs;

▪ Coordinates with the Universal Waste Program Manager for UW container delivery and/or pick-up;

▪ Must be familiar with this environmental management plan;

▪ Inspects each UWAA and entire facility for mismanaged UW at least once a month, document inspections, and correct deficiencies immediately;

▪ Reports mismanaged UW to the Universal Waste Program Manager;

▪ Ensures facility tenants are aware of proper UW management as described in this environmental management plan;

▪ Affixes signs at all UWAAs, as described within Appendix I – Universal Waste

Accumulation Management Sign;

▪ Ensures that UW is placed in containers only when the UW is exactly as described on container labels; and

▪ Remains aware that placement of UW not accurately described by container labels may be a violation of federal regulation.

Hazardous Waste Management Plan 21

5 TRAINING

5.1

Hazardous waste training is required by law. All training requirements and sources are provided in the Environmental Training Matrix on eDASH. Specific local training procedures are provided in the Installation Supplement to this plan.

5.2

Hazardous waste training is provided only by qualified authorized personnel. Training records are maintained IAW the Recordkeeping and Reporting section of this plan.

5.3

Hazardous waste program managers and alternates appointed in writing by the installation

Commander to sign manifests, require specific training to include HW Management Compliance

Training and Department of Transportation training to sign HW manifests. Installation HW

Program Managers should complete the following in-residence courses (or equivalent): Air

Force Institute of Technology (AFIT) 521, Hazardous Waste Management; and DLA -

DCPSO00510, Transportation of Hazardous Material/Hazardous Waste (Interservice

Environmental Education Review Board [ISEERB] approved). After initial course completion, refresher training is required annually for RCRA, and every 3-years for the DoT course. See training matrix for more information.

5.4

Function-Specific Training (Local In-House/On-Line Training Sources): (Group A)

Organizational (non-central) Hazardous Waste Storage Area Managers, Satellite Accumulation

Area (Initial Accumulation Point) Managers, and their immediate supervisor; and (Group B) all shop personnel, and their immediate supervisors, who generate HW.

5.5 JBER-SPECIFIC TRAINING REQUIREMENTS FOR

MILITARY, CIVILIAN, AND CONTRACTOR PERSONNEL

All military and civilian personnel whose work involves hazardous or other regulated wastes, and their immediate supervisor, must successfully complete training appropriate to their job duties; see Figure 1: Training Matrix for Key Personnel. Any individual who has not yet received

HW training shall not perform any duties related to HW unless doing so under the direct supervision of a trained individual. All training records will be maintained in accordance with the Recordkeeping and Reporting section of this environmental management plan.

Hazardous Waste Management Plan 22

All contractor personnel whose work involves hazardous or other regulated wastes, and their immediate supervisor, must successfully complete training appropriate to their job duties. Any individual who has not yet received HW training shall not perform any duties related to HW unless doing so under the direct supervision of a trained individual. The prime contractor is responsible for ensuring all contract personnel are trained in accordance with federal Hazardous

Waste Regulations (40 CFR § 262.17(a)(7) and 40 CFR § 273.36) and Hazardous Material

Regulations (49 CFR § 172.704), if applicable. All training records will be maintained in accordance with the Recordkeeping and Reporting section of this environmental management plan.

Hazardous Waste Management Plan 23

Figure 1: Training Matrix for Key Personnel

NOTES: ✓ = Required Training / * = Required Training (select one only).

HW

Program

Manager

UW

Program

Manager

Personnel

Authorized to Sign

Uniform

Hazardous

Waste

Manifests

CAA

Personnel

Primary and

Alternate

HW

Managers

Pharmacy

Personnel with HW

Duties

All Other

Personnel with HW

Duties

Facility

Managers

Non-

Delegated

UW Point-of-Contact

McCoy RCRA 5-

Day Seminar

McCoy RCRA 2-

Day Seminar

Air Force RCRA

Annual Refresher /

HW Accumulation

Seminar (WESS

010)

49 CFR § 172.704

Defense Transportation

Regulation (DTR)

4500.9-R, Part II, Chapter 204

40-Hour

HAZWOPER

Course (Initial)

8-Hour

HAZWOPER

(Refresher)

Air Force-

Specific

✓ One-Time

HW Management

(WENV 521)

AFMAN 32-7002,

Chapter 5, Section 6.1.5

Site-Specific ✓ ✓ ✓ ✓ ✓ * Annual

JBER HW

Manager Course 40 CFR § 262.17(a)(7)

RCRA Non-

Creditable HW

Pharmaceuticals

Only if working at a pharmacy

* Annual

JBER HW

Manager Course 40 CFR § 266.502(b)

✓ Annual Facility Manager

Training

✓ Annual

Training provided and documented by UW Program

Manager

40 CFR § 266.502(b)

40 CFR § 262.17(a)(7)

Annual 29 CFR § 1910.120

On-the-Job *

RCRA UW Only

Key Personnel

Type of

Training

Training

Frequency

Available

Course(s)

Every 3 years

Transportation of

HM/HW for DoD

(DCPSO00R510)

DoT HM

Employee

Regulatory Citation(s)

✓RCRA HW 40 CFR § 262.17(a)(7)Annual✓

OSHA

HAZWOPER

40 CFR § 273.36

Annual

Training provided and documented by a Primary /

Alternate HW

Manager

Hazardous Waste Management Plan 24

5.5.1 TIMEFRAMES FOR COMPLETING INITIAL TRAINING

Timeframes for completion of initial training will vary based upon the type of training required.

These timeframes are outlined below.

RCRA Hazardous Waste Training: If required, training must be completed within six months of the employee’s date of employment or assignment to work involving Hazardous or other regulated waste. – 40 CFR § 262.17(a)(7).

RCRA Non-Creditable Hazardous Waste Pharmaceuticals Training: If required, training must be completed prior to performing any duties related to non-creditable HW pharmaceuticals – 40

CFR § 266.502(b).

RCRA Universal Waste Training: If required, training must be completed prior to performing any duties related to UW – 40 CFR § 279.36.

DoT Hazardous Material Training: If required, training must be completed within 90-calendar days of the employee’s date of employment or change in job function – 49 CFR § 172.704.

JBER Hazardous Waste Manager Course: If required, training must be completed within 60-calendar days of appointment.

5.5.2 JBER-SPECIFIC TRAINING OPPORTUNITIES

In order to be compliant with federal regulations, JBER has several training opportunities that are conducted locally and offered throughout the year. These training opportunities include:

JBER Hazardous Waste Manager Course; Non-Creditable Hazardous Waste Pharmaceutical

Training; Universal Waste Training; Facility Manager Training; Universal Waste Training; and

On-the-Job Training. Additional information regarding each of these unique training opportunities is included below.

5.5.2.1 JBER HAZARDOUS WASTE MANAGER COURSE

The JBER Hazardous Waste Manager Course is for all military and civilian personnel who generate HW, HW pharmaceuticals, UW, or other regulated waste. This course was developed to meet the requirements outlined within 40 CFR § 262.17(a)(7), 40 CFR § 273.36, and 40 CFR §

266.502(b) and covers: roles and responsibilities; training requirements; recordkeeping requirements; waste identification and containerization; container marking and labeling;

container management; satellite accumulation area requirements; waste minimization; and spill response and reporting requirements. While Primary and Alternate Hazardous Waste Managers are required to attend this course in-person, several other key personnel may receive this training while on-the-job from a Primary or Alternate Hazardous Waste Manager. A JBER Hazardous

Waste Manager Course certificate is provided upon successful completion of the course. See

Appendix R – JBER Hazardous Waste Manager Course for additional information regarding this training opportunity.

Hazardous Waste Management Plan 25

5.5.2.2 NON-CREDITABLE HAZARDOUS WASTE PHARMACEUTICAL TRAINING

Non-creditable HW pharmaceutical training is an annual requirement for all military and civilian personnel who generate non-creditable HW pharmaceuticals. These personnel must be thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations and emergencies as outlined within 40 CFR §

266.502(b). Several key personnel to include, but not limited to, Pharmacy Personnel with HW

Duties receive non-creditable HW pharmaceutical training when they attend the JBER

Hazardous Waste Manager Course or through on-the-job training that is provided by the Primary or Alternate Hazardous Waste Manager.

5.5.2.3 UNIVERSAL WASTE TRAINING

UW training is an annual requirement for all military and civilian personnel who handle UW.

These personnel must be familiar with proper waste handling and emergency procedures, relative to their responsibilities during normal facility operations and emergencies in accordance with 40

CFR § 273.36. While most key personnel receive UW training while attending the JBER

Hazardous Waste Manger Course, Facility Managers and non-delegated UW POCs are not required to complete this course. The UW training that both Facility Managers and non-delegated UW POCs receive was developed to meet the requirements outlined within 40 CFR §

273.36 and covers: roles and responsibilities; waste identification and containerization; container marking and labeling; container management; UWAA requirements; and spill response and reporting requirements. Both Facility Managers and non-delegated UW POCs receive UW training handouts designed to re-emphasize the training received.

5.5.2.3.1 FACILITY MANAGERS

Facility Managers receive initial UW training while attending the Facility Manager Training and is documented by way of a Facility Manager Training certificate. Subsequent on-the-job UW training is received upon issuance of a UW container with the training being documented using

Appendix P – Acknowledgement of Understanding.

5.5.2.3.2 NON-DELEGATED UNIVERSAL WASTE POINTS-OF-CONTACT

Non-delegated UW POCs receive on-the-job UW training upon issuance of a UW container with the training being documented using Appendix P – Acknowledgement of Understanding.

5.5.2.4 ON-THE-JOB TRAINING

As an alternative to completing the JBER Hazardous Waste Manager Course, military and civilian personnel may complete on-the-job training when assigned duties that are related to HW and/or non-creditable HW pharmaceuticals. This training is provided by the Primary or Alternate

HW Manager and must be documented in accordance with Air Force, Army, or agency policy.

Hazardous Waste Management Plan 26

6 RECORDKEEPING AND REPORTING

RECORDKEEPING

The installation complies with the following U.S. Federal HW recordkeeping requirements as applicable based on generator status. NOTE: Retention time is defined by regulation as onsite and readily accessible for inspections and/or reference; after retention, the record(s) follow applicable Air Force Records Management rules.

Table 6-1: Summary of HW Recordkeeping Requirements

Record*

Citation

Retention Time**

Citation

HW determination documentation

40 CFR § 262.11(f)

3 years from the date that the waste was last sent to a TSDF.

40 CFR § 262.11(f)

HW Biennial/Annual

Report

40 CFR § 262.41 3 years from the due date of the report.

40 CFR § 262.40(b)

HW manifest

(electronic or paper)

40 CFR § 262.20

3 years from the day the waste was accepted by the initial transporter.

40 CFR § 262.40(e)

Small Qty HWAS inspection logs

40 CFR §

262.14(b)(2)(iv)

Although records are not formally required, the best management practice is to record and retain for 3 years to demonstrate compliance.

N/A

Large Qty HWAS inspection logs

262.17(a)(1)(v)

40 CFR § 264.15(d)

40 CFR § 265.15(d)

For interim and permitted operations, 3 years from the date the inspection was conducted. For all other LQGs, the best management practice is to retain for 3 years

40 CFR § 265.14(d)

40 CFR § 265.15(d)

Preparedness and prevention

262.16(b)(8)(iv)(B)

The federal regulations do not offer a minimum retention time, but the best management practice is to retain

N/A

Hazardous Waste Management Plan 27 arrangements with local authorities the pan while active and for 3 years thereafter to demonstrate compliance.

Consolidation of HW received from very small quantity generators.

40 CFR § 262.17(f) the HW was received from the very small quantity generator.

40 CFR § 262.17(f)

Exception Reports 40 CFR § 262.42 3 years from the due date of the report.

40 CFR § 262.40(b)

Land restricted waste determination

40 CFR § 268.7(a)(1) the determination was required to be conducted. If not required, 3 years from the date the waste was last sent to a TSDF.

40 CFR § 268.7(a)(8)

Land restricted notice and certification

40 CFR § 268.7(a)(2) the waste was last sent to a TSDF.

40 CFR §268.7(a)(8)

Notification of intent to export waste

40 CFR § 262.83(b) the HW was accepted by the initial

262.83(i)(1)(iii)

Waste export confirmation of receipt and exception reports

40 CFR § 262.83(h) the HW was accepted

Annual report

(required of primary exporters of HW)

40 CFR § 262.83(g) the HW was accepted

40 CFR

Employee training records (including

262.16(b)(9)(iii)

262.17(a)(7)(iv) permitted operations

– current personnel:

until closure of the site.

permitted operations

– former personnel: 3 years from date the

262.17(a)(7)(iv)

40 CFR § 264.16(e)

Hazardous Waste Management Plan 28 appointment letters for key personnel)

40 CFR § 264.16(d)

40 CFR § 265.16(d) individual last worked there.

For all other LQGs and SQGs, the best management practice is to retain for 3 years

40 CFR § 265.16(e)

*Permitted Treatment, Storage, and Disposal Facilities (TSDF) comply with recordkeeping requirements established in their HW permit.

**Retention Time may be extended during the course of any unresolved enforcement action or as requested by the EPA. The AF, through the Air Force Records Information Management System

(AFRIMS), requires that HW-related reports, documents, studies, HW manifests, and disposal records (including contracts) are destroyed 50 years from the date of the record. Note that the records required by law or external regulation, should be readily available on-site. Records required by AF Record Retention requirements can be archived.

Reporting

The HW Program Manager, and other designated personnel, generate needed reports from the

Enterprise Environmental, Safety, and Occupational Health - Management Information System

(EESOH-MIS).

Enforcement actions, spills, and inspections are reported via the Enforcement Actions, Spills, and Inspections Environmental Reporting (EASIER) database.

See Sections 11.2 through 11.5 for JBER-specific recordkeeping and reporting requirements.

Hazardous Waste Management Plan 29

7 PROCEDURES

This section contains procedures for managing HW from identification, accumulation, offsite transportation, and disposal. The HW Program Manager ensures that appropriate procedures are properly communicated and followed by all necessary personnel.

7.1 WASTE INVENTORY

A current waste inventory can be generated within EESOH-MIS using the Ad-Hoc Reporting

Tool or by completing the following steps:

▪ Log into EESOH-MIS, select the “Reporting” option, and select “Hazardous Waste” to generate the Waste Site Waste Stream Summary Report.

The resulting waste inventory report can be placed into Appendix B, Hazardous Waste

Streams/Profiles.

See Section 11.6 for JBER-specific information about validation of waste stream inventories and

Appendix B – Hazardous Waste Streams/Profiles for an example of the type of information stored in EESOH-MIS. Contact the Hazardous Waste Center or HW Program Manager for instructions about how to manage a new waste site or waste stream. See the instructions above for how to obtain a copy of the Waste Site Waste Stream Summary Report.

7.2 WASTE IDENTIFICATION

The HW Program Manager determines the nature of waste based on a detailed qualitative analysis of the regulated waste generating process, associated Safety Data Sheet (SDS) information, and coordination with generating activity personnel involved in the use of hazardous materials. If uncertainties about a waste stream exist, the HW Program Manager pursues waste stream sampling and analysis IAW the Waste Analysis Plan (WAP) found in

Appendix A.

The WAP details the wastes that have been evaluated and analyzed, a description of the testing and analytical methods used, the HW sampling methods used, the location of samples taken for analysis and frequency, sample documentation, sample quality assurance and quality control procedures, and sample request procedures.

Generator knowledge and the results of the WAP are used to minimize waste re-characterizations to those instances where a process change has occurred, or the waste stream is highly variable.

See Section 11.7 for JBER-specific waste identification information.

7.3 CONTAINER MANAGEMENT

Container management procedures are as follows:

Hazardous Waste Management Plan 30

▪ Containers storing HW must be in good condition and meet transportation and other applicable requirements. “Good condition” means there should be no severe rusting, no sharp-edged creases or dents, no bulging heads, and no severe structural defects

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

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

▪ Immediately transfer the contents of a leaking container to another container or over pack into a salvage drum.

▪ Containers with free liquid or drum contents on top must be cleaned or over packed in the case of a leak.

▪ Containers must remain closed at all times except when adding or removing waste.

▪ Adequate headspace must be maintained at all times when filling a container to account for content expansion.