Attachment 5 - Ansbach HWMP.pdf

USAG Ansbach, Germany Hazardous Waste Management Plan, Final Version

October 2012 updated Nov 2016

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ANS_PLN_019_HWMP_rev1.3_2016 Page I

USAG ANSBACH, GERMANY

HAZARDOUS WASTE

MANAGEMENT PLAN (HWMP)

UPDATED

NOVEMBER 2016

CONTRACT W912GB-09-D0059 Task Order 0009 for U.S. Army Corps of Engineers, Europe District

Konrad Adenauer Ring 39/ 65187 Wiesbaden

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DOCUMENT REVIEW AND REVISION LOG

Action

Review

Date

Revision

(Yes/No)

Revision

Date Revision Summary

Initial plan development. NA NA 09 Oct 07 NA

Review & Revise # 1.0 Yes 15 Oct 12 Updated entire document to include new FGS requirements.

Review & Revise # 1.1 22 Oct 2014 Yes 24 Apr 15 Changed MSDS to SDS; delete

R- & S-phrases and added H-&

P-statements for GHS, changed shelf-life laboratory

Review # 1.2 01 Mar 2016 No 01 Mar 2016

Review # 1.3 Oct 2016 Yes Nov 2016 Review, FGS Aug 2016 update no changes), additions, improvements, review and update appendices

USAG_ANS_Form 02, rev 27Jul12 THIS IS A CONTROLLED DOCUMENT.

VERIFY MOST RECENT VERSION ONLINE.

https://portal.eur.army.mil/sites/IMCOM-E-A/DPW2/EMD/default.aspx

NA Not Applicable

Document Name: USAG Ansbach Hazardous Waste Management Plan

Document Elect. ID ANS_PLN_019_HWMP_rev1.3_2016

ISO 14001 ID: 4.4.6 - 019 Original Date: 9 Oct 2007

Revision No: 1 Revision Date: Nov 2016

Review Cycle: as needed Doc Owner: DPW EMD

ARIMS Rec. No: 1200C/6+ Approval Date: 12 Dec 12

Document developed and reviewed:

Mr. Daniel Woernlein

Approval:

Karl J. Weighmann

USAG Ansbach HW Manager/DPW EMD USAG Ansbach Chief/DPW EMD

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Approvals

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

Updated By:

15 October 2012

Lisa K. Woeber

Environmental Specialist

Cardno TEC

Date

Reviewed and revised By:

17 October 2012 & 24 Apr 2015

Daniel Woernlein

Hazardous Waste Manager

DPW Environmental Management Division

USAG Ansbach

Date

Reviewed and revised By:

Daniel Woernlein

Hazardous Waste Manager

DPW Environmental Management Division

USAG Ansbach

Date

Approved By:

Gerda Koss

Acting Chief/Environmental Management

Division

USAG Ansbach

Date

October 2012 updated Nov 2016

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Record of Revisions

This HWMP must be reviewed and updated at least once every five years. Additionally, any time there is a significant change to the hazardous waste (HW) management, that change should be detailed in this plan. To fulfill this requirement, the following table is provided for tracking revisions to this plan.

Revision No.

Date Name and Title Signature Pages Affected

1 15 Oct

Lisa K. Woeber Cardno TEC

Entire Document

2 24 Apr

Daniel Woernlein

HW Manager

Entire Document

3 01 Mar

Daniel Woernlein

HW Manager

Entire Document

4 Nov

Maren Goetz

Tetra Tech

Entire Document

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Table of Contents

Document Control Page ................................................................................................. i

Approvals ii

Record of Revisions ..................................................................................................... iii

Table of Contents.......................................................................................................... iv

Appendices ..................................................................................................................... v

Acronyms and Abbreviations......................................................................................vi

Definitions .................................................................................................................. viii

Section 1 Introduction

Section 2 Key Personnel

2.1 Commander

2.2 Environmental Quality Control Committee

2.3 Directorate of Logistics

2.4 Defense Logistics Agency Disposition Services

2.5 Environmental Management Division

2.6 Environmental Officers

2.7 Appointed U.S. Army HW Signatory Representatives

2.8 Fire Protection Unit

2.9 Responsible Legal Office

2.10 Environmental Officer

2.11 Hazardous Waste Storage Area Managers (HWSAM):

Section 3 Training

Section 4 Storage and Accumulation

4.1 Container Labeling

4.2 Container Management

4.3 Containment

4.4 Hazardous Waste Accumulation Point

4.5 Hazardous Waste Storage Area

4.6 Tank Systems

4.7 Inspections

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4.8 Used Oil and Battery Management

Section 5 Transportation

5.1 Off-Post Transportation Procedures

5.2 On-Post Transportation Procedures

Section 6 Disposal

6.1 Operation of USAG-Operated Disposal Facility

6.2 Tendering of Hazardous Waste

Section 7 Documentation

7.1 Hazardous Waste Log

7.2 Hazardous Waste Generators Identification

7.3 Hazardous Waste Identification

7.4 Disposal Documentation

7.5 Contingency Plans

Section 8 References

Appendices

Appendix 1 SOP for HW Collection and Segregation

Appendix 2 List of HWSAs and HWAPs

Appendix 3 Locations of HWSAs and HWAPs

Appendix 4 Incompatible Hazardous Substances

Appendix 5 HWSA Closure Plans

Appendix 6 Examples of Inspection Checklists

Appendix 7 Waste Analysis Plan

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Acronyms and Abbreviations

AAFES Army and Air Force Exchange Services

ADR International Carriage of Dangerous Goods by Road

AER Army Europe Regulation

AR Army Regulation

ARLOC Army Location (U.S. Army)

AST Aboveground Storage Tank

CARC Chemical Agent Resistant Coating

CFL Compact Fluorescent Lamps

CLIN Contract Line Item Number

DLA Defense Logistics Agency

DoD Department of Defense

DOL Directorate of Logistics

DPW Directorate of Public Works

DS2 Decontaminating Agent

EO Environmental Officer

EMD Environmental Management Division

EMS Environmental Management System

EQCC Environmental Quality Control Committee

EWC European Waste Catalogue

FGS Final Governing Standards

HM Hazardous Material

HS Hazardous Substance

HW Hazardous Waste

HWAP Hazardous Waste Accumulation Point

HWMP Hazardous Waste Management Plan

HWPS Hazardous Waste Profile Sheet

HWSA Hazardous Waste Storage Area

SDS Safety Data Sheet

PCB Polychlorinated Biphenyls

POC Point of Contact

POL Petroleum, Oil, and Lubricants

POV Privately Owned Vehicle

PPE Personal Protective Equipment

STB Super Tropical Bleach, Decontaminating Agent

TMP Transportation Motor Pool

U.S. United States

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USAG United States Army Garrison

USEUCOM United States European Command

UST Underground Storage Tank

VAwS Ordinance on Facilities Handling Water-Endangering Substances

(Verordnung über Anlagen zum Umgang mit wassergefährdenden Stoffen)

WAP Waste Analysis Plan

WGK Water Hazard Class (Wassergefährdungsklasse)

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Definitions

Aboveground Storage Tank (AST). A tank that is not underground. A tank in an underground space that can easily be inspected or is easily accessible, including piping in an underground protecting tube, a tunnel, or a crawlspace that can easily be inspected or is easily accessible, is considered an AST. A tank that sits directly on the ground is also considered an AST.

ADR. Officially known as “The European Agreement concerning the International

Carriage of Dangerous Goods by Road”, it provides the basis for transportation of hazardous materials (HMs) criteria.

Construction Approval (Bauartzulassung) or Test of Suitability (Eignungsfeststellung).

Required from the German authorities for facilities that store, distribute, and handle water-endangering substances, unless they are classified as facilities of ordinary or conventional construction type (Anlagen einfacher oder herkömmlicher Art). This requirement does not apply if substances are only temporarily stored for shipment operations (typically

24 hours during work days), and if the respective containers comply with the requirements for dangerous goods (gefahrgutrechtlich). These requirements also do not apply to daily-use quantities in use at the work area and substances stored in minor quantities (Handgebrauch) in laboratories.

Dangerous Goods (Gefahrgut). An ADR classification for the shipment of hazardous substances (HSs) that includes both HMs (explosive, oxidizing, flammable, toxic, corrosive, irritating, sensitizing, carcinogenic, mutagenic, or posing a hazard to the environment) and hazardous wastes (HWs) (those that are specifically designated as wastes in Europe (see Final Governing Standards (FGS) C6.T3), as well as all wastes having hazardous properties).

Determination of Suitability (Eignungsfeststellung). The determination of suitability is an acceptance check by the respective German Federal State Environmental Agency

(Landesumweltamt) on facilities or equipment that is carried out prior to the start-up of an operation. The determination of suitability may be conducted for an entire facility (e.g., filling station) or for individual facility components (e.g., fuel-dispensing equipment).

Direct Removal Contract. Contract agreement between the Defense Logistics Agency

(DLA) Disposition Services and a licensed German contractor to collect and transport HW generated by the USAG to authorized German disposal facilities. USAG personnel serve as the contract monitor and the USAG is responsible for reimbursement to DLA

Disposition Services of all contract cost.

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Environmental Officer (EO). Lead person appointed by military unit commanders to ensure environmental compliance. Applies to tenant organizations also.

Environmental Quality Control Committee (EQCC). A formal board created to help plan, execute, and monitor actions and programs with environmental implications. The committee identifies issues, makes recommendations, and advises the Garrison

Commander. The membership of the EQCC is comprised of representatives from all garrison directorates, tenant organizations, and operational commands within the USAG.

Expert (Sachverständiger). An individual knowledgeable of the daily operations, applicable health and safety regulations, and the technical standards of a facility that he/she supervises or is asked to inspect. An expert shall be external to the Department of Defense

(DoD). Depending on specific criteria, an expert requires specific training or shall be registered by an appropriate German Federal State authority.

Filling Facility (Abfüllanlagen). Devices used for filling containers with Petroleum, Oil, and

Lubricants (POL) substances. These also include areas in which POL substances are filled from one container into another. There is no volume limit value that defines a filling facility.

Generating Activity. The actual organization, unit, or shop within a DoD installation that produces the waste. The generating activity is typically the activity responsible for properly managing the waste and preparing internal HW documentation.

Hazardous Material (HM). Any material capable of posing an unreasonable risk to health, safety, or the environment if improperly handled, stored, issued, transported, labeled, or disposed of because it displays a characteristic listed in FGS C5.T1, “Typical Hazardous

Material Characteristics.” Munitions are excluded.

Hazard Sign (Warnzeichen). A sign posted at workplaces where HMs are stored or handled that warns against a specific risk or danger (i.e., risks or dangers associated with flammables, toxics, irritants, oxidizers, compressed gases, batteries, or explosive atmosphere hazard). See FGS Appendix C5.A1.

Hazard Statements (H-Sätze). The hazard statement is part of a HM container label standardized under the Globally Harmonized System of Classification and Labeling of

Chemicals (GHS) for international products. The hazard statement indicates the physical, health or environmental hazards associated with the particular material. The hazard statement replaces the former R-phrases (R-Satz) for non-U.S. products

Hazard Symbol (Gefahrensymbol). Orange sign indicating the type of hazard associated with each container.

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Hazardous Substance (HS). Hazardous substances include both hazardous materials and hazardous waste. HS = HM + HW

Hazardous Waste (HW) (gefährliche Abfälle). Wastes listed in the USEUCOM Waste List and denoted by an asterisk (*) added to the six-digit waste code (see https://www.us.army.mil/suite/files/20917769).

Hazardous Waste Accumulation Point (HWAP). A shop, site, or other workcenter where

HW is accumulated until removed to a hazardous waste storage area (HWSA) or shipped for treatment or disposal. An HWAP may be used to accumulate ≤208 liters (55 gallons) of

HW, or 1 liter (1 quart) of acute HW, from each waste stream. The HWAP must be at or near the point of generation and under the control of the operator.

Hazardous Waste Generation. Any activity or process that, during the course of operations, produces HW as defined in the FGS.

Hazardous Waste Log. A list of HW deposited and removed from an HWSA. Information such as the waste type, volume, location, and storage removal dates should be recorded.

Hazardous Waste Profile Sheet (HWPS). A document which identifies and characterizes the waste by providing user’s knowledge of the waste and/or laboratory analysis, and which details the physical, chemical, and other descriptive properties or processes that created the HW.

Hazardous Waste Storage Area (HWSA). One or more locations on a DoD installation where HW is collected and stored prior to shipment for treatment or disposal. An HWSA may store >208 liters (55 gallons) of an HW stream, and >1 liter (1 quart) of an acute HW stream. The requirements for storage, distribution and handling facilities as described in

Chapter 5, Hazardous Materials, are also applicable to HWSAs.

Hazardous Waste Storage Area Manager. A person, or agency, on the installation assigned the operational responsibility for receiving, storing, inspecting, and general management of the installation’s HWSA or HWSA program.

Identification Number. A unique number assigned to each generating activity and generator of HW and used to assist in tracking the waste from point of generation to ultimate disposal.

Mandatory Sign (Gebotszeichen). A sign placed at a workplace where HMs are stored or handled that indicates that a certain behavior shall be followed (for example, the use of specific personal protection equipment (i.e., safety masks, goggles, or gloves) or special precautionary measures). (See FGS Appendix C5.A2)

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Safety Data Sheet (SDS) (Sicherheitsdatenblatt). A form prepared by manufacturers or importers of chemical products to communicate to users the chemical and physical properties of the product and the hazardous effects of a particular product. SDSs for HMs with national stock numbers can be obtained from the Hazardous Material Information

Resource System available on CD through the Directorate of Public Works (DPW), Environmental Management Division (EMD).

Official Leaflet (Merkblatt). Operators of facilities that store, distribute, and/or handle water-endangering substances in Bayern, Hessen, and Rheinland-Pfalz shall permanently affix the officially published operating procedures (Merkblatt) “Instructions for the Use and

Safe Handling of Water-Endangering Substances” (Betriebs- und Verhaltenvorschriften beim

Umgang mit wassergefährdenden Stoffen) in conspicuous places in the vicinity of facilities and shall inform facility personnel of the contents. In Bayern, this applies only to facilities that supply residential buildings or similarly used buildings with heating oil

(Heizölverbraucheranlagen).

Operating Instructions (Betriebsanweisung). Workplace-specific instructions that provide information on handling HS as well as information on risks for human health and the environment associated with HS handled at each specific workplace.

Ordinary and Conventional Facilities (einfache und herkömmliche Anlagen). Facilities storing, distributing, and/or handling water-endangering substances designed and constructed so that the risk of water pollution is low. See FGS Appendix C5.A3 for detailed criteria.

Precautionary Statements (P-Sätze). The precautionary statement is part of a HM container label standardized under the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) for international products. The intent of the precautionary statement is giving advice about the correct handling of chemical substances and mixtures. The hazard statement replaces the former S-phrases (S-Satz) for non-U.S. products

Pollution Prevention. Any established technical and/or administrative practice that reduces or eliminates the creation of pollutants through increased efficiency in the use of raw materials, energy, water, or other resources.

Safety Sign (Sicherheitszeichen). A sign that addresses information regarding health and safety concerns. A safety sign consists of a combination of a geometric shapes and colors with a hazard symbol. A safety sign may be a hazard sign (Warnzeichen) or a mandatory sign (Gebotszeichen). See FGS Appendix C5.A1 and Appendix C5.A2.

Secondary Containment (Auffangvorrichtung). Leakproof structures, rooms in buildings

(fluid retention rooms), and / or prefabricated building components (collecting vats

(Auffangwannen)) designed to collect leaking substances from containers or piping, and

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ANS_PLN_019_HWMP_rev1.3_2016 Page xii leakproof drainage areas designed to channel leaking substances from containers or pipelines into collection devices (e.g., holding tanks, sumps).

Special Wastes (Sondermüll or Sonderabfälle). In Germany, special wastes are substances that are not allowed to be disposed of in the regular municipal landfill. This includes a much wider range of substances as defined by U.S. law as HW. Oil and grease must be handled as special wastes.

Transshipment Facilities (Umschlagsanlagen). Areas and equipment used for the loading and unloading of water-endangering substances from one transport vehicle to another

(e.g., from a rail tank car to a tank truck), either as bulk loads or as packaged products.

Underground Storage Tank (UST) (Unterirdische Tankanlage). A facility that is wholly- or partially-embedded in the ground, without restriction with respect to volume. This does not include gutters and sewers that cannot easily be inspected. A storage tank sitting on the ground is not considered an UST.

USEUCOM Waste List. A list available online of waste types (see https://www.us.army.mil/suite/files/20917769). Each waste is defined by a six-digit

USEUCOM Waste List code, with two digits each for chapter, subchapter, and waste type.

The USEUCOM Waste List is used to categorize items and substances when they become waste, but does not itself define items any substances as waste.

Water-Endangering Substances. Water-endangering substances are all substances classified under Water Hazard Class 1 to 3 (see Definition Water Hazard Class).

Water Hazard Class (Wassergefährdungsklasse - WGK). Classification of substances based on their potential for endangering water resources as outlined below. (For lists of water-endangering and non-water-endangering substances, see https://www.us.army.mil/suite/files/ 20917769.)

Water Hazard Class Description Examples

WGK 1 Low hazard rating for water e.g., antifreeze, battery acid, detergent, DS2, some paints

WGK 2

Medium hazard rating for water e.g., brake and hydraulic fluids, lube oil, grease, STB, toluene, some paints and thinners

WGK 3 High hazard rating for water e.g., many pesticides, chlorinated solvents, waste oil

Water Hazard Category (Wassergefährdungsstufe). Classification of facilities based on the

Water Hazard Class (WGK) of the HM stored, and the volume of HM in cubic meters (m³) or mass in metric tons as one of the four Water Hazard Categories A through D. A has the lowest; D has the greatest potential to cause damage to the environment. The classification

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ANS_PLN_019_HWMP_rev1.3_2016 Page xiii is dependent on State-specific regulations. According to the FGS (Table C5.T2) and

Ordinance on Facilities Handling Water-Endangering Substances (Verordnung über Anlagen zum Umgang mit wassergefährdenden Stoffen – VAwS) for Bavaria the classification is presented as follows.

Volume in m³ or mass in metric tons

Water Hazard Class (WGK)

1 2 3 less than 0.1 A A A between 0.1 and 1.0 A A B between 1 and 10 A B C between 10 and 100 A C D between 100 and 1,000 B D D more than 1,000 C D D

Notes:

1 m3 = 35.3 ft3 = 264.2 gallons

1 metric ton = 2,204.6 pounds

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Section 1 Introduction

This Hazardous Waste Management Plan (HWMP) has been developed for the United

States Army Garrison (USAG) Ansbach’s current and planned hazardous waste (HW) generation and disposal activities. The Environmental Management Division (EMD) of the USAG Ansbach is responsible for development, maintenance, and implementation of this HWMP.

The purpose of a HWMP is to outline policies and procedures for proper handling, storage, and disposal of HW. This HWMP addresses the regulatory requirements of the

Environmental Final Governing Standards (FGS) for Germany, Chapter 6, Hazardous

Waste. Chapter 6 of the FGS contains cross-references to Chapter 5, Hazardous Materials, and Chapter 7, Solid Waste.

The HWMP should be used in combination with a USAG-specific Solid Waste

Management Plan for effective overall management of waste generated by the USAG

Ansbach. The USAG Ansbach’s Solid Waste Management Plan is available in the EMD.

Throughout this HWMP, all subsequent citations from the FGS for Germany are simply referred to as the "FGS." In addition, it should be noted that the nomenclature for FGS section numbers includes a reference to both the FGS chapter and paragraph (e.g., FGS

C6.2.2 refers to FGS Chapter 6, Paragraph 6.2.2).

In addition, this HWMP meets the requirements of USAG Ansbach’s Environmental

Management System (EMS) providing responsibilities and procedures for the management of hazardous waste within the Garrison. The EMS Policy letter no. 8, dated

11 July 2013, requirements are met in the fielding of this HWMP.

Hazardous waste generated at USAG Ansbach is recycled and/or reprocessed to the maximum extent practical and disposed of such that risks to human health or the environment are minimized. The majority of the hazardous waste streams generated are mainly disposed of through Defense Logistics Agency (DLA) Disposition Services. The

USAG Ansbach has developed strategies for reduction of hazardous waste disposal. When feasible, authorized agencies are used for the recycling of hazardous waste, which includes the following waste reduction strategies:

Recycling of dry cell batteries through the German “Stiftung GRS Batterien”.

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Recycling of lead-acid batteries through the new DLA Disposition Services’ battery sales contract.

Recycling of printer cartridges through the Caritas Box donation program.

Recycling of light tubes, bulbs and compact fluorescent lamps (CFL) through the

German industry return system.

Recycling of electronic scrap and refrigerators through the German industry return system.

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Section 2 Key Personnel

This section details the primary USAG’s key personnel with regard to HW management and their responsibilities. Additional minor roles such as Fire Department or Safety Office are not specifically addressed.

2.1 Commander

The USAG Ansbach commander is the Environmental Quality Control Committee (EQCC) chairperson, and, as the garrison commander, is ultimately responsible for HW management and compliance. The following items are the specific responsibility of the

USAG Ansbach commander:

Ensure the usage of proper HM and HW management practices.

Ensure that HW generators and facility operators are aware of and comply with regulatory requirements (U.S. and HN) and USAG directives for HW management.

Ensure that the Directorate of Public Works (DPW) personnel have sufficient support to carry out their functions.

Ensure all personnel engaged in operations involving handling of HW are appropriately and fully instructed and receive the annual refresher courses.

Require all tenant commanders to designate Environmental Officers (EOs) and alternate EOs.

Appoint in writing (using DD Form 577) qualified representative(s) to sign the HW shipping documents (i.e., manifest) and ensure they have the appropriate training.

Develop and implement an installation HW minimization program.

Establish and maintain a garrison recycling and reuse program.

Reduce the volume or quantity and toxicity of waste as much as possible before disposal. Reduction will be done using economically practicable methods that emphasize source reduction, recycling, and reuse.

2.2 Environmental Quality Control Committee

The Environmental Quality Control Committee (EQCC) meets quarterly and is chaired by the USAG Ansbach Commander. In general, the EQCC acts on the broad range of

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ANS_PLN_019_HWMP_rev1.3_2016 Page 17 environmental issues covered in the Army Regulation (AR) 200-1 and the Army in Europe

Regulation (AER) 200-1.

The EQCC will assume the following responsibilities in relation to the HWMP:

Recommend changes to HM and HW management practices related to health and safety considerations, or environmental protection.

Provide recommendations that may be incorporated in future updates to the community’s HWMP.

Provide recommendations to improve training, HM inventory, HW minimization, recycling and disposal.

2.3 Directorate of Logistics

The Directorate of Logistics’ (DOL) will assume the following responsibilities in relation to the HWMP:

Ensure that Safety Data Sheet (SDS) for HM procured through DOL is supplied by the manufacturer.

Designate particular HMs as banned, or restricted, as appropriate to eliminate certain

HWs.

Screen all HM orders and attempt to replace with less toxic or non-HM.

Ensure that all supplies issued by DOL to customers have SDSs.

Serve as EQCC member.

Promote community recycling program.

2.4 Defense Logistics Agency Disposition Services

The Defense Logistics Agency (DLA) Disposition Services’ will assume the following responsibilities in relation to the HWMP:

• Act as contract representative for the firm contracted for off-site disposal of HW.

• Act as monitor of the USAG Ansbach’s Hazardous Waste Profile Sheets (HWPSs) assigning the serial numbers.

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• Coordinate with EMD to analytically test waste streams with unknown contents using a contract laboratory analysis to assist in the preparation of the HWPS and to seek the least costly disposal method.

• Inspect and receive wastes as denoted on the DD 1348-1a(s) for inclusion on the DD 1155.

• Generate the delivery order (DD 1155) for removal of HW and provide copies to the

EMD and the DLA Disposition Services waste disposal contractor.

• Coordinate the hazardous waste pick-up with the HW disposal contractor and the

USAG Ansbach EMD.

• Provide copies of the filled out DD 1155s and the signed disposal documents (e.g.

accompanying documentation, acceptance slips, disposal manifests) after the pick-up.

• Ensure contractor-provided containers are secure, operational and properly labeled.

2.5 Environmental Management Division

The Environmental Management Division (EMD) has direct control over the HW program and has the following responsibilities (see Appendix 1, Standard Operating Procedure

(SOP) for Hazardous Waste (HW) Collection and Segregation for further details).

Ensure that the HWMP is reviewed as needed such as after a significant change in the disposal process.

Act as point of contact (POC) for EOs regarding hazardous waste.

Establish appropriate HM/HW training for EOs involved in handling HM/HW.

Assist with inspections of HW facilities as necessary.

Comply with the electronic-manifest requirement and help designated appointees obtain German signature cards for electronically signing HW manifest.

Coordinate removal actions with the DLA contracting officer’s representative (COR) and appointed signatory.

Seek to extend useable product shelf life before disposing of HW. If necessary, a representative sample will be provided to one of the SGS Germany GmbH laboratories contracted by IMCOM-E for an analysis to determine the product’s suitability for having its shelf life extended. Coordinate the placement of products back into the supply chain through the local reuse center.

Maintain copies of relevant Hazardous Waste Profile Sheets (HWPS), turn-in documents (DoD Form 1348-1A), the completed DD Form 1155, the disposal manifests

October 2012 updated Nov 2016

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ANS_PLN_019_HWMP_rev1.3_2016 Page 19 for all relevant EWC codes, the acceptance slips (Übernahmescheine), the accompanying documentation (Begleitscheine), the disposal manifest (Entsorgungsnachweis) and the officially weight tickets.

Maintain all HW training records for a minimum of 3 years after termination or transfer of personnel.

Maintain the USAG Ansbach’s Spill Prevention and Response Plan and ensure its distribution.

Coordinate spill clean-up activities with the Fire Department.

2.6 Environmental Officers

The Environmental Officers (EOs) are appointed in writing and have the following responsibilities with respect to HW (see Appendix 1, SOP for HW Collection and

Segregation for further details):

Ensure that the unit is in compliance with the FGS and all German and U.S. legal requirements where applicable.

Receive appropriate EO environmental training provided by EMD (at least one training per year) and train all members of the unit to properly handle HM or HW clean-ups, and other environmental issues.

Store and dispose HS in compliance with both FGS and Army requirements.

Implement and enforce the HWMP within the area of their responsibility.

Inspect all HW aboveground storage tanks (ASTs) every business day. Contact EMD when tanks are 75% full for disposal. Ensure AST covers are closed, seals cleaned regularly and appropriately labeled.

Inspect hazardous waste accumulation points (HWAPs) weekly (daily if subject to spills e.g., loading and unloading areas) and file the completed checklists for 3 years.

Ensure the units’ HW is properly labeled, maintained, stored and disposed off in close coordination with EMD.

Make sure that the “Internal Hazardous Waste Audit Trail” form is completed in coordination with the HW contractor when any container will be transferred from the point of origin (e.g., HWAP) to the hazardous waste storage areas (HWSAs).

Ensure the units’ HW spills are cleaned up properly and that spill reports are filled out accordingly and forwarded to the EMD in a timely manner.

October 2012 updated Nov 2016

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Ensure availability of required SDSs and operating instructions.

Provide copy of the appointment memorandum to the EMD.

2.7 Appointed U.S. Army HW Signatory Representatives

The representatives (i.e., primary and alternate) appointed as signatories have the following responsibilities with respect to HW:

Obtain required HAZ 12 (80 hours) and HAZ 15 (24 hours) training offered by ATTRS

(https://www.atrrs.army.mil/) or Unit Dangerous Goods Adviser (40 hours) certification provided by the USAREUR Safety Division.

Complete the application and identity-verification process to obtain a German signature card.

Create, edit or modify the hazardous waste manifest and the associated shipping documents related to the Garrison (Entsorgungsnachweis, Begleitschein, Übernahmeschein) within ZKS, NSUITE or any other portal.

On the day of the pick-up, the representative must be present to sign the accompanying documentation (Begleitschein, Übernahmeschein) electronically at the

HWSAs or HWAPs.

Verify that the proper hazardous waste transportation procedures in accordance with the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR) are being followed.

Alert the EMD and command at least 3 months before leaving the unit so an alternate designee can be selected, trained and apply for a German signature card.

2.8 Fire Protection Unit

Inspects, coordinates, approves/disapproves, in writing, the location or relocation of HWAP/HWSA IAW National Fire Protection Agency (NFPA)

Standards 30, 43, 49, 490 and Unified Facilities Criteria 3-600-1 through the use of AF Form 1768 provided by the generating activity.

Participates in HW training programs and exercises.

2.9 Responsible Legal Office

Evaluates, reviews and ensures proper interpretation of German environmental laws

Advises commanders of any potential liabilities associated with failure to comply with

HW management regulations.

October 2012 updated Nov 2016

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Reviews official inquiries from authorities concerning the HW management program.

2.10 Environmental Officer

Assume overall responsibility for management of the HWAP.

Ensure HWAP has an appropriate spill response kit to contain the HW stored onsite.

Ensure an approved fire extinguisher is readily available for HWAPs that accumulate or store ignitable HW.

Perform at a minimum and document weekly inspections of the HWAPs.

Ensure HWs are collected and stored in approved containers.

Ensure HW is in appropriate (authorized) containers capable of being loaded and transported IAW FGS and ADR transportation requirements.

Maintain HW storage/transportation containers in proper condition; e.g. no pitting, sharp edges, creases, material defects.

Ensure HW containers are kept closed and secure by closing the lid and clamping ring except when they are being emptied or filled.

Ensure HW is placed in an approved HWAP.

Ensure HW is placed in a container that is properly marked. There must never be a doubt about the contents of a container holding HW.

a) Leased, reusable containers furnished by the removal contractor WILL NOT be permanently marked through the use of stencils or other non- removable markings without first obtaining written permission Nonpermanent markings, such as hanging or magnetic signs, may be utilized to mark these containers.

Ensure the placement of a new HW container in a HWAP is accompanied by a simultaneous entry of the placement in the container log. Continue updating the log entry for containers until the waste is picked up by the contractor or taken to a HWSA.

Under no circumstances shall a HW container be placed in a HWAP without a proper entry in the log.

Ensure arrangements are made to move full containers of HW to an approved HWSA or ship it offsite for treatment or disposal in a timely manner.

Implement emergency response. When a HW spill is detected, stop other actions and contain the spill to the best ability based on unit capability, resources and procedures described in the USAG Ansbach Red Plan. Activate the installation's response process by calling the Garrison Fire Department at 112.

Develop operating instructions to cover proper handling, storage, use, spill response and cleanup of HW in the HWAPM’s area of responsibility.

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2.11 Hazardous Waste Storage Area Managers (HWSAM):

Assume overall responsibility for management of the HWSA.

Receive HW from generating activities IAW this plan.

Coordinate the location or relocation of the HWSA.

Manage HW in their custody IAW the FGS requirements and the HWMP.

Ensure HWSA has appropriate warning signs that they are visible from all angles.

Ensure HWSA has an appropriate spill response kit to contain the HW stored onsite.

Ensure an approved fire extinguisher is readily available for HWSAs that accumulate or store ignitable HW.

Perform and document inspections of the HWSA weekly for HW containers and daily for tanks and also prior to each use.

Ensure HWs are collected and stored in approved containers. Leased, reusable containers for waste disposed of under the removal contract must be requested. Other containers should be obtained by your UHWM through normal supply channels.

Ensure HW is in appropriate (authorized) containers capable of being loaded and transported IAW FGS and ADR transportation requirements.

Maintain HW containers in proper condition; e.g. no pitting, sharp edges, creases, material defects, bulging heads and/or dents (more than 2 inches).

Ensure HW containers are kept closed and secure except when they are being emptied or filled.

Ensure HW is placed in an approved HWSA.

Ensure HW is placed in a container that is properly marked. There must never be a doubt about the contents of a container holding hazardous materials or HW.

a) Ensure HW containers are properly marked and labeled before they receive any HW or prior to accepting them for storage. Mark the container with information as described under chapter 4.1.

b) When shipping overpacks or other containers with inside packaging containing liquid HW, mark the outside container with an arrow symbol to indicate the upward position of the openings of the inside packaging.

c) Leased, reusable containers furnished by the removal contractor WILL NOT be permanently marked through the use of stencils or other non-removable markings without first obtaining written permission. Nonpermanent markings such as hanging or magnetic signs may be utilized to mark these containers.

Ensure placement of a new HW container in their HWSA is accompanied by a simultaneous entry of the placement in the container log. Continue updating

October 2012 updated Nov 2016

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ANS_PLN_019_HWMP_rev1.3_2016 Page 23 the log entry for containers until the waste is picked up by the contractor or taken offsite for treatment or disposal. A HW container shall not be placed in any HWSA without a proper entry in the container log.

Provide initial HW management awareness training to shop personnel who handle HW.

Implement emergency response. When a HW spill is detected, stop other actions and contain spill to best ability based on unit capability, resources and procedures described in the USAG Ansbach Red Plan Activate installation's response process by calling the Base Fire Department at 112.

Minimize HW generation through prudent management of HM under their control.

Obtain copies, maintain and comply with applicable FGS requirements.

Develop operating instructions to cover proper handling, storage, use, spill response and cleanup of HW in their areas of responsibility.

Maintain HW documentation and correspondence for a minimum of 3 years after the closure of the HWSA. Have available for inspection by the following

HW management compliance agencies.

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Section 3 Training

All personnel who are or have the potential to be involved in handling, storage, and disposal of HW are required to receive appropriate training before assuming work duties involving exposure to HW. Verbal instructions over the operating instructions are given to all local national employees working with HW prior to initiating work. All personnel performing HW duties complete annual refresher trainings.

Training is performed by qualified personnel either from the EMD or contracted. The training program includes sufficient information to enable personnel to perform their assigned tasks while complying with HW requirements. Personnel are instructed in the following key areas:

Emergency Procedures: response to fire/explosion/spills, use of communications/alarm systems, body and equipment clean-up

Safe use of HW equipment: drum/container handling/storage, proper sampling procedures

Employee Protection: personal protective equipment, safety and health hazards, hazard communication, worker exposure

Recordkeeping, security, inspections, contingency plans, storage requirements, transportation requirements

Training courses, attendees, and dates of completion are documented. EMD personnel maintain HW training records for at least three years after the termination of employees.

The training records are maintained by EMD personnel.

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Section 4 Storage and Accumulation

The USAG Ansbach operates currently 20 hazardous waste accumulation points (HWAPs) and 3 hazardous waste storage areas (HWSAs). EMD personnel are primarily responsible for the setup and maintenance of the HWAPs and the HWSAs, although individual EOs are assigned responsibility for assisting in the HW handling. Appendix 2 contains a list of the active HWAPs and HWSAs located throughout the USAG Ansbach. Appendix 3 contains maps that indicate where storage areas are located throughout the USAG

Ansbach. The following pages detail the HW management and storage operations at the

USAG Ansbach.

4.1 Container Labeling

The HW contractor typically provides the HW collection containers that are already labeled for HW that is to be transported offsite. In addition, the EMD provides appropriately labeled ASTs for waste oil, waste fuel, used anti-freeze and used hydraulic oil which contents are pumped out by a various contractors. The EMD Hazardous Waste

Manager ensures that containers provided by the HWcontractor, must also be labeled in accordance with the FGS, Chapter 6 and include the following information:

• The term “Hazardous Waste”

• Waste nomenclature

• European Waste Code (EWC) number

• Container start date

• Container full date

• ADR shipping label (provided by contractor)

• Hazard class warning label

4.2 Container Management

The following container management requirements apply at the USAG Ansbach.

To the extent possible, all containers used to collect HW at HWAPs and HWSAs are approved in accordance with The European Agreement concerning the International

Carriage of Dangerous Goods by Road (ADR) with the exception of the ASTs which are used for stationary collection of HW.

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Containers are arranged with proper aisle width (at least one meter). In areas in which material-handling equipment is used, aisle widths are at least three meters or one meter wider than the largest piece of material handling equipment used, whichever is greater.

Containers holding HW are in good condition and free from severe rusting, building, and structural defects.

Containers used to store HW, including overpack containers, are compatible with the materials stored.

Containers are kept in the closed position at all times, unless adding or removing waste.

Sufficient room is left in containers storing liquid for the contents to have room to expand with temperature increases.

All containers are opened, handled and stored in a manner that prevents rupturing or leaking.

Containers used for storage of flammable liquids are grounded during the transfer from one container into another.

Containers used to accumulate ignitable or reactive wastes are stored in a HWAP or

HWSA that is at least 15 meters (50 feet) inside the installation’s boundary.

Incompatible wastes (see Appendix 4 for guidelines) are stored in segregated containers and do not share secondary containment structures. Where necessary, incompatible wastes are physically separated using berms, dikes, walls, or other similar means.

HWs are not placed in an unwashed container that previously held incompatible wastes. All packaging, including containers used for shipment of HW, are free from contamination, regardless whether the contaminant is hazardous or non-hazardous.

Areas where containers are stored are inspected weekly for leaking and deteriorating containers as well as deterioration of the containment system caused by corrosion or other factors. Secondary containment systems are inspected for defects and emptied of accumulated releases or retained stormwater.

4.3 Containment

Container storage areas at USAG Ansbach have secondary containment systems that meet the following requirements:

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Secondary containment systems are sufficiently impervious to contain leaks, spills and accumulated precipitation until the collected material is detected and removed.

Secondary containment systems have sufficient capacity to contain 10% of the volume of stored containers or the volume of the largest container, whichever is greater.

Storage areas that store containers holding only wastes that do not contain free liquids and do not have a secondary containment system, either have a sloped floor or are designed and operated to drain and remove liquid resulting from precipitation, or the containers are elevated or are otherwise protected from contact with accumulated liquid.