Attachment 15 JBER Hazardous Waste Management Plan - 7 May 2020.pdf

JOINT BASE ELMENDORF – RICHARDSON (JBER)

HAZARDOUS WASTE MANAGEMENT PLAN

673D AIR BASE WING

JBER AK 99506

7 May 2020

OPR: 673 CES/CEIEC

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Attachment 15 - JBER Hazardous Waste

Management Plan

(INTENTIONALLY BLANK)

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DEPARTMENT OF THE AIR FORCE

HEADQUARTERS, JOINT BASE ELMENDORF-RICHARDSON

JOINT BASE ELMENDORF-RICHARDSON, ALASKA

22 April 2020

MEMORANDUM FOR 673 ABW/XP

FROM: 673 CES/CD

SUBJECT: Request to waive JBERI 10-409 formatting for JBER Hazardous Waste Management Plan (HWMP)

1. The Joint Base Elmendorf-Richardson Hazardous Waste Management Plan (JBER HWMP) cannot be formatted IAW JBERI 10-409. The Air Force Civil Engineer Center (AFCEC) provides a standardized template (updated October 2018) in accordance with AFCEC Environmental Directorate Business Rule 08, EMP Review, Update, and Maintenance that installation HWMPs are required to follow. To comply with guidelines this plan conflicts with local plans formatting guidance.

2. For any questions or concerns regarding this memorandum, please contact Mr. Scott Tarbox at DSN 317-384-3322.

MARK A. PRIEKSAT, PhD, USAF Deputy Commander

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JBER HAZARDOUS WASTE MANAGEMENT PLAN

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. This plan is not an inventory of all hazardous waste (HW) requirements and practices. Where applicable, external resources, including Air Force Instructions (AFIs); AF Playbooks; and federal, state, local, 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 HW Program Manager.

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

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TABLE OF CONTENTS

ABOUT THIS PLAN

DOCUMENT CONTROL

STANDARDIZED HWMP TEMPLATE

INSTALLATION HWMP

1.0 OVERVIEW AND SCOPE

2.0 INSTALLATION PROFILE

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

4.0 ROLES AND RESPONSIBILITIES

4.1 INSTALLATION SUPPLEMENT – GENERAL ROLES AND RESPONSIBILITIES

4.1.1 Waste Managers

4.1.2 Unit Environmental Coordinator (UEC)

4.1.3 Central Accumulation Area Operator

5.0 TRAINING

5.1 INSTALLATION SUPPLEMENT – TRAINING

6.0 RECORDKEEPING AND REPORTING

6.1 RECORDKEEPING

6.2 REPORTING

6.2.1 Installation Supplement – Recordkeeping and Reporting

7.0 PROCEDURES

7.1 WASTE INVENTORY

7.2 INSTALLATION SUPPLEMENT – WASTE INVENTORY

7.3 WASTE IDENTIFICATION

7.3.1 Installation Supplement – Waste Identification

7.4 CONTAINER MANAGEMENT

7.4.1 Installation Supplement – Container Management

7.5 LABELING AND MARKING

7.5.1 Installation Supplement – Labeling and Marking

7.6 ACCUMULATION AREA MANAGEMENT

7.6.1 Installation Supplement – Accumulation Area Management

7.7 TRANSPORTATION

7.7.1 Installation Supplement – Transportation

7.8 TURN IN/DISPOSAL

7.8.1 Installation Supplement – Turn In/Disposal

7.9 INSPECTION

7.9.1 Installation Supplement – Inspection

7.10 WASTE MINIMIZATION

7.10.1 Installation Supplement – Waste Minimization

7.11 PREPAREDNESS AND PREVENTION

7.11.1 Installation Supplement – Preparedness and Prevention

7.12 WASTE SPECIFIC PROCEDURES

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7.12.1 Installation Supplement – Waste Specific Procedures

8.0 REFERENCES

8.1 STANDARD REFERENCES (APPLICABLE TO ALL AF INSTALLATIONS)

8.2 INSTALLATION REFERENCES

9.0 ACRONYMS

9.1 STANDARD ACRONYMS (APPLICABLE TO ALL AF INSTALLATIONS)

9.2 INSTALLATION ACRONYMS

10.0 DEFINITIONS

11.0 INSTALLATION-SPECIFIC CONTENT

11.1 JBER HAZARDOUS WASTE TRAINING REQUIREMENTS

11.1.1 JBER Waste Manager Training

11.1.2 JBER Universal Waste Training Requirements

11.2 UNIVERSAL WASTE TYPES

11.3 RECORDKEEPING AND REPORTING

11.4 HAZARDOUS WASTE RECORDS

11.5 HAZARDOUS WASTE NOTEBOOKS

11.6 WASTE STREAM INVENTORY

11.7 WASTE IDENTIFICATION AND WASTE ANALYSIS PLAN (WAP)

11.8 JBER REQUIREMENTS FOR WASTE ACCUMULATION

11.8.1 What must an organization waste manager do when the organization receives a container for hazardous waste?

11.8.2 What must an organization do when accumulating hazardous waste in a satellite accumulation area?

11.8.3 What should an organization waste manager do when the organization receives a container for universal waste?

11.8.4 What must an organization waste manager do when the organization handles universal waste?

11.9 CENTRAL ACCUMULATION AREA CONTAINER 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 HAZARDOUS WASTE 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 Bulbs

11.17.8 Used Oil

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11.17.9 Batteries

11.17.10 Toner Cartridges

11.18 WASTE GENERATED BY CONTRACTORS ON JBER

APPENDICES

Appendix A – Base Map Appendix B – EESOH-MIS Waste Stream Inventory Example Appendix C – Waste Accumulation Area Sign Appendix D – Hazardous Waste Compatibility Appendix E – Appointment and Training of Primary and Alternate Waste Managers Appendix F – Inspection Checklists Appendix G – Used Oil Management Appendix H – Oil/Water Separator User Knowledge Statement Appendix I – POL–Contaminated Soil User Knowledge Statement Appendix J – Contact Information Appendix K – Waste Container Certification Form Appendix L – Checklist for the first person observing a spill

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 10/03/2018 and supersedes the 2015 version.

NOTE: Installations are not required to update their HWMPs every time this template is updated. When it is time for installations to update their HWMPs, they should refer to the eDASH EMP Repository to ensure they have the most current version.

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.

Thereafter, the plan must be reviewed and approved annually by the Environmental Management System (EMS) Cross Functional Team (CFT) and updates/changes noted below. NOTE: This is not a Wing Contingency Plan and is not governed by installation or Wing plans or readiness format or coordination requirements of AFI 10-401, Air Force Operations Planning and Execution. It is governed by AFI 32-7042, Waste Management, Section 3.2. Hazardous Waste Management Plan.

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:

Record of Annual Review – IAW AFI 32-7042, this plan is reviewed annually by the EMS 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 EMS CFT Chair Notes/Remarks

1.0 OVERVIEW AND SCOPE

This HWMP contains procedures for management of HW. In lieu of federal, or state requirements, AFI 32- 7042, acts as the main driver for the HWMP. The HW Playbook serves as supplemental guidance to this plan.

Installation Supplement – Overview and Scope

Joint Base Elmendorf-Richardson (JBER) is a large quantity generator (LQG) of hazardous waste as defined by Title 40 Code of Federal Regulations (CFR) 260.10. There are approximately 220 hazardous waste satellite accumulation areas (SAAs) regulated in accordance with 40 CFR 262.15, and one central accumulation area (CAA) regulated in accordance with 40 CFR 262.17. In addition, there are hundreds of accumulation areas for universal waste, used oil, and recyclable material. The number of accumulation areas changes as the amount of waste and material changes to support the mission. Current information about accumulation areas may be viewed in the Enterprise Environment, Safety and Occupational Health – Management Information System (EESOH-MIS). JBER has received permit authorization, from the U.S.

Environmental Protection Agency (EPA), to operate a hazardous waste container storage unit in one location, building 11735 Vandenberg Avenue. JBER is responsible for all hazardous waste management activities that occur on JBER. The hazardous waste container storage unit is operated by the Defense Logistics Agency Disposition Services (DLA-DS) for JBER, and is not covered in this HWMP. The Base map, Appendix A, depicts the location of the CAA, and building 11735.

Waste generation processes include, but are not limited to, maintenance of vehicles, aircraft, facilities, and equipment; corrosion control/painting; construction; and training activities. Organizations and personnel generating waste off JBER are prohibited from transporting waste to JBER.

Regardless of the quantity of hazardous waste generated by a specific person, contractor, or organization, all hazardous waste generated on JBER must be managed in accordance with regulations applicable to LQGs of hazardous waste.

Regardless of the quantity of universal waste handled by a specific person, contractor, or organization, all universal waste must be managed in accordance with the standards applicable to large quantity handlers of universal waste.

The Installation Commander is responsible to ensure compliance with all Resource Conservation and Recovery Act (RCRA) requirements on JBER. Implementation of a comprehensive HWMP requires

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maximum cooperation of all activities on JBER. Therefore, commanders, and leaders, of all organizations (military, civilian, tenant, and contractor) are responsible for proper management of waste their organizations generate. Commanders and leaders are responsible to implement actions necessary to comply with waste regulations and this plan. If a regulatory agency takes enforcement action due to a violation of hazardous waste regulation, the organization causing the violation may, as determined by JBER leadership personnel, potentially be responsible for associated financial penalties (fines) and corrective actions imposed by a regulatory agency.

All organizations are required to have a primary, and at least one alternate waste manager, regardless of whether the organization knowingly generates waste or believes it will not generate hazardous or universal waste. Commanders/leaders must appoint waste managers in accordance with Appendix E of this plan.

The HW 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 HWMP and applicable regulation. The office of the HW Program Manager is located in building 724 Quartermaster Road, as depicted in the map in Appendix A. Contact information for the HW Program Manager and others is Appendix J of this plan.

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

• Reduce cost and risk when practicable

2.0 INSTALLATION PROFILE

Table 2.0-1: Installation Profile

Scope of Plan This plan applies to all military organizations, civilian organizations, tenants, and contractors, working on JBER, regardless of whether they are permanently assigned to JBER or operating on JBER temporarily. All organizations, tenants, and contractors, are required to comply with this plan.

OPR 673 CES/CEIEC has overall responsibility for implementing the HWMP and is the lead organization for monitoring compliance with applicable federal, state, and local regulations.

HW Program Manager Scott Tarbox, 673 CES/CEIEC, (907) 384-3322 Alternate HW Program Manager Lucas Oligschlaeger, 673 CES/CEIEC, (907) 384-2445 Emergency contacts In the event of a spill, fire, or explosion involving hazardous waste, dial 911 and indicate the incident is on JBER.

The first person to observe a spill will complete the checklist shown in Appendix L.

For additional contact information, please see Appendix J.

Waste registration numbers EPA identification number AK8570028649 HW generator status Large quantity generator Universal waste handler status Large quantity handler Permitted HW operations Hazardous waste container storage, no longer than 365 days at building 11735, EPA ID No. AK8570028649 Federal regulatory references Title 40 CFR Parts 260 – 279 (40 CFR Parts 260 – 279 ) State and local regulatory agencies State of Alaska is not authorized by EPA to regulate hazardous waste.

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Table 2.0-1: Installation Profile

State and local regulatory references None applicable Approved HW disposal contractors DLA-DS contractors HW accumulation sites JBER’s central accumulation area is located at building 4314

Kenney Avenue.

Approximately 220 satellite accumulation areas and hundreds of areas for accumulation of other waste throughout JBER. Current information is maintained in EESOH-MIS.

HW accumulation time limits - Unlimited in satellite accumulation areas (when the volume does not exceed limits shown in 40 CFR 262.15)

- 90 days in a central accumulation area

HW generator reporting frequency 2 years, during Biennial hazardous waste reporting (no later than 1 March of each even-numbered year)

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

The AF environmental program adheres to the 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 Organization for Standardization (ISO) 14001, Environmental management systems - Requirements with guidance for use, provide guidance on how environmental programs should be established, implemented, and maintained to operate under the EMS framework.

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

4.0 ROLES AND RESPONSIBILITIES

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

• Wing/Installation Commander

• ESOHC

• HW Program Manager/Alternate

• 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 (DLA) Disposition Services

• Tenant Organizations

• AFCEC

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

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4.1 INSTALLATION SUPPLEMENT – GENERAL ROLES AND RESPONSIBILITIES

Waste Managers, Unit Environmental Coordinators, and the central accumulation area operator have JBER-specific responsibilities identified below and throughout this plan.

4.1.1 Commanders/Leaders of Generating Activities

• Organization commanders/leaders will appoint Unit Environmental Coordinators (UEC) per AFI 32- 7001 Environmental Management

• Ensures that a primary and at least one (1) alternate Waste Managers are formally appointed (refer to Appendix E). Allows facilities, shops, and equipment to be inspected for hazardous waste management regulatory compliance by installation fire, safety and health personnel, HW Program manager, and authorized inspectors.

• Submits written requests to the HW Program Manager to establish an initial SAA

• Provides safe equipment and locations for Accumulation Areas.

• Identifies funding requirements for HW equipment and allocates funds based upon regulatory requirements.

• Requires management of HW accumulation areas to comply with federal HW management regulations and with this plan.

• Ensures 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 Section 5.0 and Appendix E.

4.1.2 Waste Managers

Waste managers are responsible for supporting the obligation of their organization commander/leader to comply with this plan and all HW regulations. These requirements include the general responsibilities outlined below and the specific compliance responsibilities specified in this plan.

• Serve as the focal points for the organization’s waste management activities.

• Coordinate with the HW Program Manager to ensure that existing and new waste streams are properly determined to be either hazardous or nonhazardous at the point of generation of the waste.

• Must be familiar with this plan.

• Attend JBER HW training as required by Appendix E.

• Inspect each waste accumulation area at least once every 7 calendar days, and document inspections.

• Train other organization personnel, as described in this plan.

• Maintain documentation of all inspections and training, and provide documentation of inspections and training upon a request made by JBER Environmental staff or regulatory agency personnel.

• Place signs, as described within Appendix C of this plan, at all waste accumulation areas.

• Ensure that waste placed in containers only when waste is exactly as described on container labels.

• Remain aware that placement of waste not accurately described by container labels may be a violation of federal regulation.

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• Ensure that waste generation, accumulation, pickup, and recordkeeping, comply with all applicable policies, regulations, laws, and this plan.

• Coordinate with the HW Program Manager, Fire Prevention, Bioenvironmental Engineering, and applicable Safety office during the placement (or relocation) of a waste accumulation area.

• Notifies the HW Program Manager of all changes in activities including, but not limited to, the location of a new waste accumulation area, relocation of an existing waste accumulation area, 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 another waste manager in accordance with Appendix E of this plan.

• Corrects deficiencies to ensure compliance with HW regulations and this plan.

• Provide completed and signed waste container certification forms and user knowledge statements as required by this plan.

• Contact the JBER HW Program Manager when he/she has a question about waste management or desires compliance assistance.

4.1.3 Unit Environmental Coordinator (UEC)

UEC responsibilities are defined in AFI 32-7001. JBER-specific UEC responsibilities are to:

• Ensure the organization commander/leader has appointed a primary and at least one alternate waste manager in accordance with Appendix E of this HWMP;

• Ensure the waste managers attend initial and annual review of initial training as required by Appendix E of this plan.

• Notify the organization commander/leader and the JBER HW Program Manager when a waste manager has not had training within the previous 365 days.

• Ensure waste managers inspect each waste accumulation area at least once every 7 calendar days.

• Certify descriptions of waste generating processes.

• Fulfill obligations identified through the JBER Environmental Management System

4.1.4 Central Accumulation Area Operator

The operator of the central accumulation area supports the JBER HW Program Manager and:

• Ensures accumulation of waste in the central accumulation area in accordance with 40 CFR 262.17;

• Provides waste containers and container labels

• Obtains waste samples and waste analysis;

• Inspects the central accumulation area as required by 40 CFR 262.17;

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

• Assists the HW Program Manager with data needs and data calls;

• Maintains an inventory of waste accumulated in the central accumulation area;

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

• Establishes and maintains waste profiles;

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• 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 central accumulation area;

• Packages and labels waste for transportation in accordance with applicable regulation;

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

• Inspects waste accumulation throughout JBER and communicates findings to the HW

Program Manager;

• Provides advice to waste generators on JBER;

• Assists the HW Program Manager with exception reporting and required documentation when applicable;

• Provides initial HW training, universal waste training, and annual review of initial HW training, applicable to proper waste management on JBER; and

• Maintains required documentation which may include, but is not limited to, waste analysis, waste profiles, inspection documentation, uniform HW manifests, nonhazardous waste manifests, bills of lading, shipping documentation, waste exception reporting, training records, and appointments of primary and alternate waste managers.

5.0 TRAINING

HW awareness training is provided to satisfy regulatory 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. HW Program Managers require specific training to include HW Management Compliance Training and Department of Transportation training to sign HW manifests. Consistent with the eDASH training matrix, 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). Installations will enter procedures regarding site-specific training requirements below based upon Federal, State, and local regulations, consistent with the eDASH training matrix.

5.1 INSTALLATION SUPPLEMENT – TRAINING

See Section 11.1 for JBER-specific training requirements.

6.0 RECORDKEEPING AND REPORTING

6.1 RECORDKEEPING

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

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Table 6.1-1: Installation Profile

Record* Citation Retention Time** Citation

HW determination documentation

40 CFR 262.11(f) 3 years from the date that the waste was last sent to a TSDF

40 CFR 262.11(f)

HW Biennial/Annual Report

40 CFR 262.41 3 years from the due date of the report 40 CFR 262.40(b)

HW manifest (electronic or paper)

40 CFR 262.20 3 years from the day the waste was accepted by the initial transporter

40 CFR 262.40(a)

Small Quantity Generator CAA inspection logs

40 CFR

262.16(b)(2)(iv)

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

N/A

LQG CAA inspection logs

40 CFR

262.17(a)(1)(v) 40 CFR 264.15(d) 40 CFR 265.15(d)

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

40 CFR 265.14(d) 40 CFR 265.15(d)

Preparedness and prevention arrangements with local authorities

40 CFR

262.16(b)(8)(vi)(B)

The federal regulations do not offer a minimum retention time, but the best management practice is to retain the plan while active and for 3 years thereafter to demonstrate compliance

N/A

Consolidation of HW received from very small quantity generators.

40 CFR 262.17(f) 3 years from the date the HW was received from the very small quantity generator

40 CFR 262.17(f)

Exception reports 40 CFR 262.42 3 years from the due date of the report 40 CFR 262.40(b)

Land restricted waste determination

40 CFR

268.7(a)(1)

3 years from date the determination was required to be conducted. If not required, 3 years from the date the waste was last sent to a TSDF

40 CFR

268.7(a)(8)

Land restriction notice and certification

40 CFR

268.7(a)(2)

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

40 CFR

268.7(a)(8)

Notification of intent to export waste

40 CFR 262.83(b) 3 years from the date the HW was accepted by the initial transporter

40 CFR

262.83(i)(1)(i)

Waste export confirmation of receipt and exception reports

40 CFR 262.83(h) 3 years from the date the HW was accepted by the initial transporter

40 CFR

262.83(i)(1)(iii)

Annual report (required of primary exporters of

HW)

40 CFR 262.83(g) 3 years from the date the HW was accepted by the initial transporter

40 CFR

262.83(i)(1)(ii)

Employee training records (including appointment letters for key HW personnel)

40 CFR

262.16(b)(9)(iii)

40 CFR

262.17(a)(7)(iv) 40 CFR 264.16(d)

For interim and permitted operations-current personnel: until closure of the site; Former personnel: 3 years from date the individual last worked there. For all other LQGs and SQGs, the best

40 CFR

262.17(a)(7)(iv) 40 CFR 264.16(e) 40 CFR 265.16(e)

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Table 6.1-1: Installation Profile

Record* Citation Retention Time** Citation 40 CFR 265.16(d) management practice is to retain for 3 years to demonstrate compliance *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.

6.2 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.

6.2.1 Installation Supplement – Recordkeeping and Reporting

See Sections 11.3 through 11.5.

7.0 PROCEDURES

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

7.1 WASTE INVENTORY

A current waste inventory can be generated within EESOH-MIS using the Ad-Hoc Reporting Tool or by completing the following steps:

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

7.2 INSTALLATION SUPPLEMENT – WASTE INVENTORY

See Section 11.6 for information about validation of waste stream inventories and Appendix B for an example of the type of information stored in EESOH-MIS. Contact the CAA or the 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 a Waste Site Waste Stream Summary Report.

7.3 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 Section 11.7. 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.

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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.

7.3.1 Installation Supplement – Waste Identification

See Section 11.7.

7.4 CONTAINER MANAGEMENT

Container management procedures are as follows:

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

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

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

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

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

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

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

• 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.

7.4.1 Installation Supplement – Container Management

See Sections 11.8 through 11.16.

7.5 LABELING AND MARKING

Containers used for the accumulation and transportation of HW are properly labeled IAW applicable laws and regulations.

Each container is properly marked and labeled at a SAA prior to transportation to a CAA. The waste-generating activity ensures that the label on each waste container is clearly visible for inspection. During accumulation at a SAA, HW containers are marked with the following:

• The words “Hazardous Waste”

• A description of the contents of the container

• An indication of the hazards of the contents

7.5.1 Once a HW satellite accumulation area accumulates more than 55 gallons of HW (or more than 1 quart of liquid acute HW, or more than 1 kilogram of solid acute HW), the waste manager marks the container with the date on which 55 gallons (or 1 quart of liquid acute HW, or 1 kilogram of solid acute HW) is exceeded. The amount of HW that exceeds 55 gallons (or 1 quart of liquid acute HW, or 1 kilogram of solid acute HW) must be transported to a CAA or a TSDF within three consecutive calendar days. Refer to section 11.8.2 “What must an organization do when accumulating hazardous waste in a satellite accumulation area?”

HW containers 110 gallons or less that are shipped offsite are marked with the following:

• “Hazardous Waste – Federal Law prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency”

• Generator’s name and address

• Generator’s EPA ID Number

• Manifest tracking

These markings are:

• Durable

• In English

• Printed on or affixed to the surface of a package or on a label, tag, or sign displayed on a background of sharply contrasting color

• Unobscured by labels or other attachments

• Located away from any other markings that might substantially reduce visibility or effectiveness

Universal waste (UW), or a container in which a UW is contained, is labeled and marked clearly with the date the material became a waste and the name of the waste, as described below:

• UW batteries must be labeled with any one of the following phrases: “Universal Waste— Battery(ies),” or “Waste Battery(ies),” or “Used Battery(ies)”

• UW thermostats must be labeled with any of the following phrases: “Universal Waste- Mercury Thermostat(s),” “Waste Mercury Thermostat(s),” or “Used Mercury Thermostat(s)”

• UW pesticides must be labeled with one of the following phrases: “Universal Waste— Pesticide(s)” or “Waste-Pesticide(s)”

• UW lamps must be labeled with one of the following phrases: “Universal Waste— Lamp(s),” or “Waste Lamp(s),” or “Used Lamp(s)”

7.5.2 Installation Supplement – Labeling and Marking

See Sections 11.8 through 11.11.

7.6 ACCUMULATION AREA MANAGEMENT

Accumulation area management procedures are as follows:

• SAAs are used to accumulate up to 55 gallons of HW or 1 quart of liquid acute HW, or kilogram of solid acute HW

• If HW or acute HW are accumulated in excess of these amounts, the generator marks the container with the date the amount was exceeded and transfers the container to a CAA or TSDF within 3 consecutive calendar days

• HW is accumulated in a CAA for up to 90 days for a LQG (LQG), or 180 days (270 days if waste has to be shipped over 200 miles) for a small quantity generator (SQG)

• CAAs comply with all applicable federal, state, and local accumulation requirements, including proper waste segregation

7.6.1 Installation Supplement – Accumulation Area Management

See Sections 11.8 through 11.13.

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7.7 TRANSPORTATION

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

• All transportation over public highways is conducted IAW applicable Department of Transportation (DOT) requirements

• Containers are DOT approved

• Transporters have the appropriate training

• Uniform HW manifests are prepared for offsite transportation (electronically or paper)

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

7.7.1 Installation Supplement – Transportation

See Section 11.13 through 11.15.

7.8 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.

7.8.1 Installation Supplement – Turn In/Disposal

See Sections 11.13 through 11.14.

7.9 INSPECTION

Inspection processes fulfill the “Check” function of the EMS “Plan, Do, Check, Act” cycle. CAAs are inspected at least weekly to ensure proper accumulation and container management. Resource Conservation and Recovery Act (RCRA) Part B permitted storage facilities are inspected according to the inspection schedule established in the permit. All other inspections occur IAW AFI 90-201, The Air Force Inspection System, and the Commander’s Self Inspection Program. Inspection records are maintained IAW the Recordkeeping and Reporting section of this plan.

7.9.1 Installation Supplement – Inspection

See Section 11.16.

7.10 WASTE MINIMIZATION

HW manifests include certification that a waste minimization program is in place. Below are key activities and processes that are performed as part of waste minimization and pollution prevention efforts:

• Hazardous material process authorization and hazardous materials management processes

– Each process involving use of hazardous materials and generation of waste streams is evaluated and authorized. Process authorization is performed through EESOH-MIS. The HW Program Manager, Hazardous Materials Management Program (HMMP) Team, and the generating activity make a final determination whether or not the results of the process authorization effort are sufficient to reduce waste toxicity and volume

FA500021R0023 - JBER MACC

• Procurement and use of minimal quantities – When a material with environmental risk must be used, minimal quantities are procured to minimize surplus quantities and shelf life exceedances

• Recycling – When the use of hazardous materials is unavoidable, excess or waste material is evaluated for reuse or recycling

• Environmental action planning – Environmental action plans (EAPs) are developed and maintained as part of the overall EMS. EAPs are management plans that translate environmental objectives and targets into actionable plans. Waste minimization efforts are considered during development of EAPs

7.10.1 Installation Supplement – Waste Minimization

To meet the regulatory requirement to have a waste minimization program, JBER implements a Hazardous Materials Management Process (HMMP). All organizations are required to obtain approval through the HMMP to possess and use hazardous materials on JBER. For additional information, contact the Hazardous Materials Program Manager in 673 CES/CEIEC. Contact information is in Appendix J.

7.11 PREPAREDNESS AND PREVENTION

Preparedness and prevention practices are described in emergency prevention and response plans available through the references section of this plan and are maintained IAW the EMS on eDASH: Emergency Preparedness and Response, and shall include the Installation Spill Prevention, Control, and Countermeasure (SPCC) Plan (or equivalent) or a specific HW Contingency Plan.

7.11.1 Installation Supplement – Preparedness and Prevention

Each organization is required to provide spill response equipment as appropriate to respond to a spill of the type of waste generated, accumulated, or handled by the organization. Funding for the purchase of spill response supplies and equipment is the responsibility of each applicable organization. Many organizations may be able to purchase spill response supplies and equipment at the JBER GSA SERVMART. Contact information is in Appendix J. In addition, numerous industry vendors sell spill response supplies and equipment.

To meet preparedness, prevention and emergency procedures requirements, JBER implements an Installation Emergency Management Plan/Continuity of Operations Plan (IEMP/COOP) 10-2, a Base Civil Engineer Contingency Response Plan /Continuity of Operations Plan (BCE CRP/COOP), and a Spill Prevention, Control and Countermeasures Plan/Oil Discharge Prevention and Contingency Plan. Those three plans are available through the JBER Plans and Programs SharePoint site https://jber.eis.pacaf.af.mil/673ABW/XP/673%20ABW%20XPX%20Wing%20Plans/673%20ABW%20 Plans/Forms/AllItems.aspx.

In the event of a HW spill (regardless of size), a person discovering a spill will immediately notify JBER Fire and Emergency Services, Fire Alarm Communication Center, by dialing 911 and indicating the spill is on JBER. This will ensure appropriate cleanup and notification measures. The first person observing a spill should report information and take action as shown in the checklist in Appendix L of this plan.

Organizations and/or Squadron Commanders/Directors/Leaders will reimburse Civil Engineering for initial and intermediate clean-up response and waste disposal expenses if environmental quality funds are used.

7.12 WASTE SPECIFIC PROCEDURES

Waste-specific procedures are included in the installation supplement below or maintained as separate operational controls outside of this plan.

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Attachment 15 - JBER Hazardous Waste

Management Plan https://jber.eis.pacaf.af.mil/673ABW/XP/673%20ABW%20XPX%20Wing%20Plans/673%20ABW%20Plans/Forms/AllItems.aspx https://jber.eis.pacaf.af.mil/673ABW/XP/673%20ABW%20XPX%20Wing%20Plans/673%20ABW%20Plans/Forms/AllItems.aspx

7.12.1 Installation Supplement – Waste Specific Procedures

See Sections 11.17 through 11.18.

8.0 REFERENCES

8.1 STANDARD REFERENCES (APPLICABLE TO ALL AF INSTALLATIONS)

• Advanced Distributed Learning Service (ADLS)

• AFI 32-7001, Environmental Management

• AFI 32-7042, Waste Management

• AFI 32-7086, Hazardous Materials Management

• AFI 90-201, The Air Force Inspection System

• AFLOA HW Legal and Other Requirements – The Air Force Legal Operations Agency

(AFLOA) legal registry lists and provides access to federal (e.g., CFR, U.S. Code), DoD, AF, and other legal requirements

• ARCNet – Training resource for Air Force Reserve Command

• DoD 4160.21 (all volumes), Defense Materiel Disposition

• EASI Database (includes SIRIS)

• eDASH HW Environmental Action Plans (EAPs)

• eDASH HW Home Page

• eDASH HW Training Matrix

• EESOH-MIS Application Login

• EESOH-MIS Support Portal

• The Environmental Awareness Course Hub (TEACH)

• HW Playbook

8.2 INSTALLATION REFERENCES

• AF Form 55, Environmental Health and Safety Record

• DD Form 1348-1A

• DRMS Form 1851

• DRMS Form 1930, Hazardous Waste Profile Sheet

• EPA Form 8200-22, Uniform Hazardous Waste Manifest

• EPA Form 8700-13 A/B

• JBER Installation Emergency Management Plan/Continuity of Operations Plan

(IEMP/COOP) 10-2

• 673 CEG Base Civil Engineer Contingency Response Plan /Continuity of Operations

Plan (BCE CRP/COOP)

• JBER Spill Prevention, Control and Countermeasures Plan/Oil Discharge Prevention and

Contingency Plan

• RCRA HW Permit

• Enterprise Environmental, Safety, and Occupational Health Management Information

System (EESOH-MIS)

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Attachment 15 - JBER Hazardous Waste

Management Plan https://golearn.adls.af.mil/login.aspx http://static.e-publishing.af.mil/production/1/af_a4/publication/afi32-7001/afi32-7001.pdf http://static.e-publishing.af.mil/production/1/af_a4/publication/afi32-7042/afi32-7042.pdf http://static.e-publishing.af.mil/production/1/af_a4_7/publication/afi32-7086/afi32-7086.pdf http://static.e-publishing.af.mil/production/1/saf_ig/publication/afi90-201/afi90-201.pdf https://cs2.eis.af.mil/sites/10040/Lists/AFLOALegal/AllItems.aspx?FilterField1=Program%5Fx0020%5FArea&FilterValue1=Hazardous%20Waste https://www.my.af.mil/arcnetprod/resnet/classic/home.asp http://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodm/416021_vol1.pdf https://www.my.af.mil/accgeoprod7/easi/ https://cs2.eis.af.mil/sites/10040/WPP/EAPTool/Program%20View.aspx?Program=Hazardous%20Waste https://cs2.eis.af.mil/sites/10040/WPP/ProgramPage/ProgramPage.aspx?Program=Hazardous%20Waste https://cs2.eis.af.mil/sites/10040/Lists/TrainingMatrix/AllItems.aspx#InplviewHash65323bbe-355e-426a-8149-404a71109972=FilterField1%3DProgram%255Fx0020%255FArea-FilterValue1%3DHazardous%2520Waste https://www.my.af.mil/esoh/eesoh/ http://www.eesoh-mis.com/ https://usaf.learningbuilder.com/ https://cs2.eis.af.mil/sites/10041/CEPlaybooks/HWMP/Pages/Overview.aspx

9.0 ACRONYMS

9.1 STANDARD ACRONYMS (APPLICABLE TO ALL AF INSTALLATIONS)

• eDASH Acronym Library

• HW Playbook – Acronym Section

• U.S. EPA Terms & Acronyms

9.2 INSTALLATION ACRONYMS

• ABW – Air Base Wing

• CAA – Central accumulation area

• CEIEC - Environmental Compliance Section

• CEG – Civil Engineer Group

• CES – Civil Engineer Squadron

• CFR – Code of Federal Regulations

• DLA-DS - Defense Logistics Agency - Disposition Services

• DOT – Department of Transportation

• EESOH-MIS – Enterprise Environmental, Safety, and Occupational Health, Management

Information System

• EPA – Environmental Protection Agency

• HAZMART – Hazardous Materials Pharmacy

• HW – Hazardous Waste

• HWPS – Hazardous Waste Profile Sheet

• HMMP - Hazardous Materials Management Process

• JBER – Joint Base Elmendorf-Richardson

• LDR – Land disposal restriction

• LQG – Large quantity generator

• OWS – Oil water separator

• PCB – Polychlorinated biphenyl

• POC – Point of Contact

• POL - Petroleum, oil, and lubricant

• RCRA - Resource Conservation and Recovery Act

• SAA – Satellite Accumulation Area

• SDS – Safety Data Sheet

• UW – Universal waste

10.0 DEFINITIONS

Standard Definitions (Applicable to all AF Installations)

• HW Playbook – Definitions Section

Installation Definitions

FA500021R0023 - JBER MACC

Attachment 15 - JBER Hazardous Waste

Management Plan https://cs2.eis.af.mil/sites/10040/_layouts/15/start.aspx#/Lists/Acronym/AllItems.aspx https://cs2.eis.af.mil/sites/10040/_layouts/15/start.aspx#/Lists/Acronym/AllItems.aspx https://cs2.eis.af.mil/sites/10041/CEPlaybooks/HWMP/Pages/PlaybookProcesses.aspx?PrintOrder=25 https://cs2.eis.af.mil/sites/10041/CEPlaybooks/HWMP/Pages/PlaybookProcesses.aspx?PrintOrder=25 http://ofmpub.epa.gov/sor_internet/registry/termreg/searchandretrieve/termsandacronyms/search.do https://cs2.eis.af.mil/sites/10041/CEPlaybooks/HWMP/Pages/PlaybookProcesses.aspx?PrintOrder=26 https://cs2.eis.af.mil/sites/10041/CEPlaybooks/HWMP/Pages/PlaybookProcesses.aspx?PrintOrder=26

None applicable.

11.0 INSTALLATION-SPECIFIC CONTENT

All commanders/leaders must appoint waste managers and ensure waste managers attend training in accordance with Appendix E of this plan.

11.1 JBER HW TRAINING REQUIREMENTS

All personnel whose work involves hazardous or other regulated wastes, and their immediate supervisors, must successfully complete waste training appropriate to their job duties. Until a person has been trained, the person may only handle HW under the supervision of a trained individual. Training requirements, for personnel that sign HW manifests, are identified in AFI 32-7042. Training requirements for central accumulation area personnel are found in 40 CFR 262.17(a)(7). Personnel preparing HW for shipment must receive Department of Transportation (DOT) training applicable to the level of the work as prescribed by the DOT regulations IAW 49 CFR subpart H, Training, and the Defense Transportation Regulation (DTR) DoD Regulation 4500.9-R, Part II, Chapter 204, Hazardous Materials, and additional details are found in AFI 32-7042. If a RCRA HW permit is in effect, training requirements, applicable to personnel working in a permitted HW unit, are identified in the permit or applicable regulation.

11.1.1 JBER Waste Manager Training

Training will include information about:

• Making proper waste determinations and identification of hazardous characteristics;

• Waste and container management applicable to HW satellite accumulation areas;

• Waste and container management applicable to universal waste accumulation;

• Regulatory requirements;

• Container marking/labeling;

• Waste minimization;

• Container deliver and waste pickup; and

• Spill response/reporting.

• Hazardous Materials Management Process (HMMP)

Waste managers will train other organization personnel to properly manage waste generated and handled by the organization, as appropriate to the responsibilities of the other personnel.

11.1.2 JBER Universal Waste Training Requirements

All personnel handling universal waste must be trained to be thoroughly familiar with proper waste handling and emergency procedures, relative to their responsibilities during normal facility operations and emergencies, as required by 40 CFR 273.36. Universal waste includes certain types of waste batteries (not alkaline), waste lamps, waste mercury-containing equipment, and waste pesticides. The most common types of universal waste on JBER are fluorescent lamps (also known as bulbs or light tubes) and rechargeable batteries. As required by the CFR, personnel must attend, and be able to document, training prior to handling universal waste. In other words, no person will handle universal waste until after receiving training relative to his/her job responsibilities. Primary and alternate waste managers are required to attend training, and are afterward required to train organization personnel that handle universal waste (including, but not limited to, fluorescent bulbs/tubes, and batteries). Each organization is required to (1) maintain documentation of all universal waste training in a HW notebook at each location in which waste is

FA500021R0023 - JBER MACC

accumulated; and (2) provide documentation of universal waste training upon a request made by JBER Environmental staff or regulatory agency personnel.

11.2 UNIVERSAL WASTE TYPES

There are four types of universal waste: batteries, pesticides, mercury-containing equipment, and lamps.

Universal waste batteries are very common on JBER, and include, but are not limited to:

• lithium batteries;

• nickel-metal hydride batteries;

• nickel-cadmium batteries; and

• all rechargeable batteries.

Alkaline batteries are not universal waste. See Section 11.17.9 for additional information about batteries.

Universal waste pesticides may include recalled and unused pesticides. Universal waste pesticides are not common on JBER.

Universal…