Attachment 5 - Aviano Hazardous Waste Management Plan Effective 20200401.pdf

“Return With Honor”

10 Feb 20

MEMORANDUM FOR 31 FW

FROM: 31 FW/CC

SUBJECT: 31 FW Hazardous Waste Management Plan

1. Attached is the 31 FW Hazardous Waste Management Plan. This plan outlines the responsibilities, policies and procedures for managing hazardous waste at Aviano AB. This plan supersedes 3201-18, Hazardous Waste Management Plan.

2. This plan fulfills the requirements established by AFI32-7042, Waste Management. The installation specific content of this standardized Hazardous Waste Management Plan has been prepared by 31 CES/CEIE.

3. This plan is effective for implementation upon reqeipt. This plan will be disposed of IAW DoD 5200.1R Information Security Program and AFI31-401 Information Security Program management when superceded or recinded.

4. The OPR for this plan is 31 CES/CEIE and can be reached at DSN 632-5394.

DANIEL T. LASICA

Brigadier General, USAF Commander

Attachment:

31 FW Hazardous Waste Management Plan

DEPARTMENT OF THE AIR FORCE

31ST FIGHTER WING (USAFE)

U. S. AIR FORCE

OVERSEAS HAZARDOUS WASTE MANAGEMENT PLAN

Aviano Air Base

4/1/2020

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 for overseas installations. This plan is not an inventory of all hazardous waste (HW) requirements and practices. External resources, including Air Force Instructions (AFIs); AF Playbooks; Final Governing Standards (FGS); and permit requirements, are referenced.

Each section of this plan begins with standard language that addresses AF and Department of Defense (DoD) policy and federal requirements. The standard language is restricted from editing to ensure consistent application across the AF enterprise. Standard language is maintained by the Air Force Civil Engineer Center (AFCEC) designated Subject Matter Expert (SME) for this plan.

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

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

TABLE OF CONTENTS

DOCUMENT CONTROL

1.0 OVERVIEW AND SCOPE

2.0 INSTALLATION PROFILE

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

4.0 ROLES AND RESPONSIBILITIES

5.0 TRAINING

6.0 RECORDKEEPING AND REPORTING

7.0 PROCEDURES

7.1 Waste Inventory

7.2 Waste Identification

7.3 Container Management

7.4. Labeling and Marking

7.5 Hazardous Waste Management

7.6 Transportation

7.7 Turn In/Disposal

7.8 Inspection

7.9 Waste Minimization

7.10 Preparedness and Prevention

7.11 Waste Specific Procedures

8.0 REFERENCES

9.0 ACRONYMS

10.0 DEFINITIONS

11.0 INSTALLATION-SPECIFIC CONTENT

APPENDICES

Appendix A – Waste Analysis Plan

Appendix B – Hazardous Waste Locations (TWSA and HWAPs)

Appendix C – Sample Forms and Templates

Appendix D – TWSA Closure Plan

Appendix E – Common Waste Streams

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 by the HW and Environmental Overseas 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

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:

0 Plan has been completely revised to comply with overseas standardized template and to align with new hazardous waste contract.

Approved on 02/13/2020 with an effective date of 4/1/2020

31 FW/CC

(ESOHC Chair)

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Record of Annual Review – IAW AFI 32-7042, Waste Management, this plan is reviewed annually by the Environmental Management System (EMS) Cross Functional Team (CFT). Formatting and administrative changes should be noted in the above record of updates as approved by the EMS CFT Chair and do not require Installation Commander or Environmental Safety and Occupational Health Council (ESOHC) approval. Substantive revisions require coordination and approval by the Installation Commander as determined by the EMS CFT Chair and/or IAW host installation procedures.

Record of EMS CFT Annual Review

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

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1.0 OVERVIEW AND SCOPE

This HWMP contains procedures for management of HW. In addition to the FGS requirements, or the Overseas Environmental Baseline Guidance Document if no FGS exists, AFI 32-7042 acts as a main driver for the HWMP. The HW Playbook serves as supplemental guidance to this plan.

Installation Supplement – Overview and Scope

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

Applicability for Aviano Air Base

This plan was established to implement an effective and comprehensive HW management program at Aviano Air Base (AB) to ensure all tasks are being carried out according to U.S. Air Force (USAF), European Union (EU), and Final Governing Standards Italy (FGS-I) requirements and operating procedures.

All personnel at Aviano AB (military, US civilians, local-national civilians and contractors), including tenant activities and Temporary Duty (TDY) units, will comply with the responsibilities and procedures stipulated herein, and will support this plan's implementation.

Areas of Aviano Air Base where Hazardous Wastes are Routinely Generated

Aviano AB includes multiple areas characterized by different activities required for mission support purposes. Currently, activities that routinely generate HW only occur at five areas (Area 1, C, F, G and the Furnishings Management Office) that are described below:

• Area 1 – Consists of schools, recreational facilities, offices, shops, and the medical clinic

• Area C – Location of Civil Engineering technical offices and operational shops

• Area F – Commonly referred to as the flight line, is the largest area of Aviano AB. Area F is the site of all activities related to aircraft operations, including maintenance and refueling as well as flight operations, runways, and maintenance shops for ground support equipment. Area F also includes a shopping center, residential buildings, and related support facilities.

• Area G – Location for munitions storage

• Furnishings Management Office (FMO) – An off-base leased facility used for storage and repair of household furnishings, including appliances.

Applicability for Ghedi Air Base

The 704th Munitions Maintenance Squadron (704 MUNSS) is a tenant unit on the Italian Air Base at Ghedi, Italy. The 704 MUNSS provides direct support under North Atlantic Treaty Organization (NATO) to the 102nd and 154th Fighter-Bomber Squadrons of the Italian Air Force (ITAF). HW generated as part of 704 MUNSS operations are disposed of via ITAF using the same procedures as other ITAF units at Ghedi.

Defense Logistics Agency - Disposition Services (DLA-DS) does not provide HW removal services at this location. Organizationally, the 704 MUNSS falls under the 52nd Munitions Maintenance Group at Spangdahlem Air Base, Germany, and not Aviano AB. Because 704 MUNSS does not fall under Aviano AB and is located on a different installation, this HWMP does not apply to 704 MUNSS. A discussion of 704 MUNSS at Ghedi Air Base is only included in this overview and scope section to clarify previous misunderstandings regarding the applicability of this HWMP to 704 MUNSS.

Applicability for Camp Darby

The 731st Munitions Squadron (731 MUNS) is a tenant unit at Camp Darby, Italy. The 731 MUNS maintains a conventional munitions stockpile for United States Air Forces in Europe (USAFE) as well as serviceable munitions for war reserve stocks for allies. HW generated as part of 731 MUNS operations are disposed of via DLA-DS using Camp Darby HW management procedures. Organizationally, 731 MUNS falls under the 31st Maintenance Group of the 31st Fighter Wing located at Aviano AB. However, because 731 MUNS is utilizing Camp Darby HW management procedures, this HWMP does not apply to 731 MUNS. For USAF internal waste reporting purposes, 731 MUNS utilizes the Aviano AB HW Generator Department of Defense Activity Address Code (DoDAAC) FH5301 when submitting waste turn-in documents to DLA-DS. A discussion of 731 MUNS at Camp Darby is only included in this overview and scope section to clarify previous misunderstandings regarding the applicability of this HWMP to 731

MUNS.

Aviano AB Environmental Office (31 CES/CEIE), Annual Review Procedures

The Aviano AB Environmental Office (31 CES/CEIE) HW Program Manager annually conducts an internal review of the HWMP. The following sections and tables must be reviewed prior to the annual review by the EMS CFT to ensure accuracy and consistency.

• Section 2 – Installation Profile

• Section 4 – General Roles and Responsibilities

• Section 8 – Installation References

• Appendix B – Hazardous Waste Locations (Temporary Waste Storage Area [TWSA] and

Hazardous Waste Accumulation Points [HWAPs])

• Appendix C – Sample Forms and Templates

• Appendix E – Common Waste Streams

• All hyperlinks to the Aviano AB eDASH Page

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

2.0 INSTALLATION PROFILE

Installation Profile

Scope of Plan All USAF personnel at Aviano AB, tenant activities, and TDY personnel

Office of Primary Responsibility

(OPR)

31 CES/CEIE has overall responsibility for implementing the HW management program and is the lead organization for monitoring compliance with applicable federal, state and local regulations

HW Program Manager Dana Holsclaw, dana.holsclaw@us.af.mil

DSN: 314-632-5394

Alternate HW Program Manager Fulvio Marchi, fulvio.marchi.it@us.af.mil

DSN: 314-632-5394

Emergency contacts Fire Department:

On Base phone: 911 Off Base phone: 0434301911

Waste registration numbers 91000190933 FGS regulatory references FGS-I, Chapter 6 Local regulatory agencies Agenzia Regionale Per l’Ambiente (ARPA) Local regulatory references None Approved HW disposal contractors Defense Logistics Agency - Disposition Services (DLA-DS) HW storage areas Building 9041, Area F HW accumulation time limits 90 days at the TWSA HW generator reporting frequency Annual mailto:dana.holsclaw@us.af.mil mailto:fulvio.marchi.it@us.af.mil

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

The AF environmental program adheres to the EMS framework and it’s 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 Organizations 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 managing associated risks, and installing a culture of continuous improvement. The HWMP serves as an administrative operational control that defines compliance-related activities and processes.

4.0 ROLES AND RESPONSIBILITIES

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

• Wing/Installation Commander

• ESOHC

• HW Manager/Alternate

• Shop/HW Generator Personnel

• Hazardous Waste Accumulation Point (HWAP) and Temporary Waste Storage Area (TWSA)

Supervisors/Managers

• Unit Commanders

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

• Contracting Officer

• DLA-DS

• 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.

Installation Supplement – Roles and Responsibilities

This section is not an all-inclusive list, but an overview, and highlights notable roles and responsibilities.

31st Fighter Wing Commander (31 FW/CC)

The 31 FW Commander is ultimately responsible for ensuring compliance with HW management laws and proper disposal from all base activities. Responsibilities include the following:

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

• Ensure all enforcement actions are resolved quickly.

• Appoints, in writing, primary and alternate personnel authorized to sign HW manifests.

Environmental, Safety and Occupational Health Council (ESOHC) Chair

• Chaired by either 31 FW/CC or 31st Fighter Wing Vice Commander (31 FW/CV).

• Reviews and approves HWMP when substantive changes are proposed.

• Assists/advises when conflicts or areas of non-compliance arise.

Environmental Management System Cross Functional Team (EMS CFT)

• Reviews HWMP, at least annually, with administrative changes annotated in the plan by the 31 CES/CEIE HW Program Manager, without need for ESOHC approval.

• Documents EMS CFT annual review in HWMP Record of Annual Review.

Staff Judge Advocate (31 FW/JA)

• Evaluates, reviews and ensures proper interpretation of Italian environmental laws, US Federal regulations, Status of Forces Agreement, and advises 31 CES/CEIE and ESOHC as to applicability of laws and regulations.

• Advises commanders of potential liabilities associated with failure to comply with HW management regulations.

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

Public Affairs Office (31 FW/PA)

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

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

• Assists 31 CES/CEIE in promoting the base HW Management Program through the use of available information media.

Contracting (31 CONS)

• Reviews all HW-related contracts to verify provisions are made IAW Federal Acquisition Regulations (FAR).

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

Logistics Readiness Squadron – HAZMART (31 LRS/LGRMSH)

• Attempts to reutilize excess hazardous materials (HM) and issues shelf-life extensions to expired HM where possible.

• If unable to reutilize HM, creates transfer documents and requests disposition in Enterprise Environmental, Safety, and Occupational Health Management Information System (EESOH-MIS) after coordinating with the 31 CES/CEIE HW Program Manager.

Installation Dangerous Goods Advisor (31 MSG/WDGA)

• Acts as a consultant and provides guidance to 31 CES/CEIE on HW movement.

• As a management best-practice, coordinates European Agreement Concerning the International

Carriage of Dangerous Goods by Road (ADR) Certifier class for 31 CES/CEIE HW Program Managers.

Occupational Safety Office (31 FW/SEG)

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

• As requested, assist with the siting and design of HWAPs IAW Section 7.5.

Base Fire Department (31 CES/CEF)

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

• Ensures all HWAPs and the TWSA are operated in compliance with applicable fire safety standards.

• As requested, assist with the siting and design of HWAPs IAW Section 7.5.

Bioenvironmental Engineering (31 AMDS/SGPB)

• Provides Hazardous Communications (HAZCOM) training to Air Force employees and identifies worker requirements for use of Personal Protective Equipment (PPE).

• Provides monitoring/oversight of base HAZCOM program as it applies to the HW program.

• Advises the 31 CES/CEIE HW Program Manager on completion of the health portions of the

Hazardous Waste Profile Sheets (HWPS), on request.

• As requested, assist with the siting and design of HWAPs IAW Section 7.5.

Commanders of Generating Activities

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

• Ensure shop supervisors, UECs, HWAP Managers, and shop personnel within their unit are performing assigned HW roles and responsibilities.

• Budget for and provide emergency spill response equipment, secondary containment and PPE for HWAPs.

• Allow assessments/inspections of HW facilities, shops and equipment for HW management and regulatory compliance by authorized assessors/inspectors.

Unit Environmental Coordinator (UEC)

• Serve as liaison between 31 CES/CEIE HW Program Manager and Shop Supervisors to ensure that HWAP Managers within their unit are trained IAW Section 5.0, properly appointed and are managing HWAPs IAW Section 7.5.

Shop Supervisors

• Ensure all personnel with HW duties receive required initial and annual refresher training IAW Section 5.0.

• Ensure HWAP Managers within their shop are properly managing HWAPs IAW Section 7.5.

• Appoint a primary and alternate manager for each HWAP IAW Section 7.5.

• Ensure that new or relocated HWAPs are approved by the 31 CES/CEIE HW Program Manager

IAW Section 7.5.

Hazardous Waste Accumulation Point Managers and Alternates

• Assume overall responsibility for management of their HWAP(s).

• Successfully complete annual HWAP Manager training IAW Section 5.0.

• Conduct annual and refresher HW Awareness training for all individuals in their activity that generate, handle, store, or have the potential to be exposed to HW IAW Section 5.0.

• Maintain a HWAP Continuity Binder IAW Section 6.0.

• Ensure proper HW container management IAW Section 7.3.

• Ensure that container HW labels and warning signs remain affixed and legible IAW Section 7.4.

• Ensure proper management of the HWAP by following the HWAP Operating Procedures IAW

Section 7.5.

• Conduct monthly inspections of their HWAP(s) IAW Section 7.8.

• Develop and maintain site-specific spill contingency plans at their HWAP(s) IAW Section 7.10.

• Comply with all other applicable provisions of this HWMP.

Civil Engineer Squadron Commander (31 CES/CC)

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

Installation Management Office (31 CES/CEI)

• Consults with tenant units and the 31 CES/CEIE HW Program Manager to determine HW support requirements during the development process of support agreements.

• Ensures that both a primary and alternate HW Program Manager are assigned within

31 CES/CEIE.

Aviano Environmental Office Hazardous Waste Program Manager (31 CES/CEIE HW Program Manager) and Alternate

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

• Provides oversight of the TWSA, Building 9041, and serves as the Facility Manager.

• Ensures HW requirements eligible for Environmental Quality (EQ) funding are properly identified and reported to Air Force Installation and Mission Support Center Detachment 4, Civil Engineer Installation Management Flight Environmental Branch (AFIMSC Det 4/CEIE).

• Maintains routine liaison with AFIMSC Det 4/CEIE, Group Legal Office, and Public Affairs in regard to HW inspections, assessments, regulatory interpretation and problem resolution.

• Monitors DLA-DS contractor performance and reports discrepancies/concerns to Contracting Officer Representative (COR) and AFIMSC Det 4/CEIE.

• Reviews the HWMP annually, unless required more frequently, IAW Section 1.0.

• Ensures HW initial and refresher training is provided annually to all HWAP Managers IAW Section

5.0.

• Maintains TWSA and HW Program Manager records IAW Section 6.0.

• Provides technical expertise and supports hazardous waste procedures IAW Section 7.0.

• Provide annual certification of HWPS to DLA-DS representative IAW Section 7.5.

• Comply with all other applicable provisions of this HWMP.

• Requests and reviews waste characterization IAW Appendix A – Waste Analysis Plan.

Temporary Waste Storage Area Manager and Alternates (DLA-DS Contractor)

• Maintains TWSA, Building 9041, in compliance with FGS-I, DLA-DS contractual requirements and all applicable policies, regulations and laws.

• Completes annual HW training IAW Section 5.0.

• Maintains records at the TWSA IAW Section 6.0.

• Conducts weekly HWAP monitoring and pickup services IAW Section 7.5.

• Ensures proper management of the TWSA by following the TWSA Operating Procedures IAW

Section 7.5.

• Conducts TWSA inspections IAW Section 7.8.

• Ensures proper operation of the TWSA rainwater collection system IAW Section 7.10.

• Performs TWSA spill prevention and response IAW Section 7.10.

• Accepts certain wastes directly at the TWSA from base personnel IAW Section 7.11.

• Conforms to the various special waste procedures outlined in Section 7.11.

• Collects waste samples and submit results IAW Appendix A – Waste Analysis Plan.

• Complies with all other applicable provisions of this HWMP.

5.0 TRAINING

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

Installation Supplement – Training

31 CES/CEIE Hazardous Waste Program Manager Training

The 31 CES/CEIE HW Program Manager should receive initial HW training by completing the Air Force Institute of Technology (AFIT) Hazardous Waste Management Course WENV 521. Annual refresher training requirements can be satisfied by conducting the HWAP Manager training or attending USAFE HW refresher training events hosted by AFIMSC Det 4/CEIE. The 31 CES/CEIE HW Program Manager should also coordinate with the Installation Dangerous Goods Advisor (IDGA) to receive ADR Certifier training for HW shipments.

TWSA Manager Training

The Aviano AB TWSA Managers (primary and alternates) are contractors hired by DLA-DS and, per contractual requirements, are responsible for obtaining annual HW training that complies with the requirements of FGS-I Section C6.3.7.4. The TWSA Managers may choose to attend the HWAP Manager training, offered by the 31 CES/CEIE, to satisfy annual HW training requirements. However, the responsibility to be fully trained and capable to work as TWSA Managers ultimately resides upon the contractor. Regardless of method chosen to satisfy annual HW training requirements, the TWSA Managers must maintain documentation of their training at the TWSA and have this documentation readily available for inspection.

HWAP Manager Training

The HWAP Manager Training is a classroom session conducted by the 31 CES/CEIE HW Program Manager covering all topics required to meet AF requirements, FGS-I requirements and Aviano AB-specific issues. Initial and refresher training will be provided monthly by the 31 CES/CEIE HW Program Manager.

The 31 CES/CEIE HW Program Manager will provide completion certificates to the HWAP/TWSA Managers and these completion certificates must be included in TAB 2 of the HWAP Continuity Binder IAW with Section 6.0. To register for HWAP Manager training, go to the Aviano AB eDASH HW Program Area Page (to access an embedded link in adobe: right click on the link, select “copy location” from the list and paste link into your web browser).

HW Awareness Training

The HW Awareness training is a classroom and hands-on session conducted by each HWAP Manager for all employees in their shop who work with HW. A template for shop-level HW Awareness training is maintained by the 31 CES/CEIE HW Program Manager and covers all topics required to meet AF requirements, FGS-I requirements and Aviano AB-specific issues. On request, the 31 CES/CEIE HW Program Manager will individually work with each HWAP Manager to update the template with shop-specific information. As a backup to prevent loss of the shop-level training during personnel transition, the HWAP Manager must provide an electronic copy of the shop-level training to the 31 CES/CEIE HW Program Manager. The 31 CES/CEIE HW Program Manager will save and store electronic copies of the shop-level training for each HWAP on the Aviano AB eDASH Shop-Level Training Library (to access an embedded link in adobe: right click on the link, select “copy location” from the list and paste link into your web browser), which is organized by unit and then by HWAP number, for future reference. The HWAP Manager will provide initial shop-level HW training prior to individuals in their shop working with HW and will then ensure that all shop personnel are provided the shop-level HW training annually thereafter.

Training of shop personnel must be documented in TAB 2 of the HWAP Continuity Binder IAW with Section 6.0.

https://cs2.eis.af.mil/sites/10626/Aviano/WPP/ProgramPage/Hazardous%20Waste.aspx https://cs2.eis.af.mil/sites/10626/Aviano/Shared%20Documents/Forms/AllItems.aspx?RootFolder=%2Fsites%2F10626%2FAviano%2FShared%20Documents%2FHazardous%20Waste%2FSHOP%2DLEVEL%20TRAINING&FolderCTID=0x0120006ADF575615E1DC4190000ADD8102A675&View=%7B6D8563AE%2D495B%2D40DC%2DA695%2D8F5EF95E4CF1%7D

6.0 RECORDKEEPING AND REPORTING

Recordkeeping

The installation complies with the following HW recordkeeping requirements, as applicable, based on generator status. Records may be kept in either paper or electronic form.

Summary of HW Recordkeeping Requirements

Record Retention Time Citation Waste Analysis/Characterization Records

5 years FGS-I Section C6.3.6.11

Turn-In Documents (HW manifests, DD Form 1348-1A)

5 years FGS-I Section C6.3.6.10

HW Log Until closure of installation FGS-I Section C6.3.6.8

Inspection Logs 5 years FGS-I Section C6.3.6.9

Employee HW Training Records 3 years from date of termination of duties FGS-I Section C6.3.7.5

Waste Loading and Unloading Registers

5 years after the date of its last entry

FGS-I

Section C6.3.6.7

Reporting

The HW Manager, and other designated personnel, generate needed reports from EESOH-MIS.

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

Installation Supplement – Recordkeeping and Reporting

Hazardous Waste Accumulation Point Continuity Binder

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

• TAB 1 – HWAP Manager Appointment Letter o Must be signed by Shop Supervisor o See Appendix C – Sample Forms and Templates for template

• TAB 2 – Hazardous Waste Training Records o HWAP Manager training certificates. The 31 CES/CEIE HW Program Manager can be contacted if a replacement copy of the HWAP Manager training certificate is needed.

o Shop personnel training records, to include name and the dates it was received, must be kept for current employees as long as they work at the installation and for an additional three years after the date they leave the base (or stop working at a position related to HW management).

o Training records must be kept to provide evidence that the training was successfully completed;

these records must be available for internal, as well as external, inspections.

• TAB 3 – HWAP Monthly Inspections o Monthly HWAP Manager inspections will be filed here and reviewed by 31 CES/CEIE HW

Program Manager during annual oversight inspection.

o 31 CES/CEIE HW Program Manager will provide results from the annual oversight HWAP inspection.

o Keep the twelve most recent monthly inspection forms on file until reviewed by 31 CES/CEIE

HW Program Manager during annual oversight inspection.

o See Appendix C – Sample Forms and Templates for template.

• TAB 4 – Hazardous Waste Profile Sheets o Copies of HWPS generated from EESOH-MIS can be downloaded and printed from the Aviano

AB eDASH HWPS Library (to access an embedded link in adobe: right click on the link, select “copy location” from the list and paste link into your web browser).

• TAB 5 – HWAP Container Log o Maintained by the TWSA Manager as part of weekly HWAP monitoring and pickup services o See Section 7.5 for details on HWAP Container Log procedures.

o See Appendix C – Sample Forms and Templates for template.

• TAB 6 – Site-Specific Spill Plan o See Section 7.10 for details on site-specific spill plan requirements.

o 31 CES/CEIE HW Program Manager can provide assistance obtaining or developing this plan.

• TAB 7 – Copy of Aviano HWMP o In place of a printed copy, HWAP may instead include a web link to the document on the

Aviano AB eDASH HW Program Area Page (to access an embedded link in adobe: right click on the link, select “copy location” from the list and paste link into your web browser).

Temporary Waste Storage Area Records

Various TWSA records must be maintained to document compliance with FGS-I. Aviano AB maintains some of these records at the TWSA and some at the 31 CES/CEIE Environmental Office (either electronically or hard copy). Those TWSA records that 31 CES/CEIE maintains at the 31 CES/CEIE Environmental Office are considered 31 CES/CEIE HW Program Manager records and are described later in this section. The following records must be stored at the TWSA:

TWSA Manager Training Records

• See Section 5.0 for details on how TWSA Manager training records are maintained at Aviano AB.

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

TWSA Weekly Inspection Logs

• See Section 7.8 for details on how TWSA Weekly Inspection Logs are maintained at Aviano AB.

• Records of TWSA weekly inspections must be maintained for a period of 5 years.

https://cs2.eis.af.mil/sites/10626/Aviano/Shared%20Documents/Forms/AllItems.aspx?RootFolder=%2Fsites%2F10626%2FAviano%2FShared%20Documents%2FHazardous%20Waste%2FEESOH%20MIS%20Profiles&FolderCTID=0x0120006ADF575615E1DC4190000ADD8102A675&View=%7B6D8563AE%2D495B%2D40DC%2DA695%2D8F5EF95E4CF1%7D https://cs2.eis.af.mil/sites/10626/Aviano/Shared%20Documents/Forms/AllItems.aspx?RootFolder=%2Fsites%2F10626%2FAviano%2FShared%20Documents%2FHazardous%20Waste%2FEESOH%20MIS%20Profiles&FolderCTID=0x0120006ADF575615E1DC4190000ADD8102A675&View=%7B6D8563AE%2D495B%2D40DC%2DA695%2D8F5EF95E4CF1%7D

TWSA Equipment Inspection Logs

• See Section 7.8 for details on how TWSA Equipment Inspection Logs are maintained at Aviano

AB.

• TWSA Equipment Inspection Logs must be maintained for a period of 5 years.

Copy of 31 FW Hazardous Material Spill Prevention and Response Plan (HMSPRP)

Installation Hazardous Waste Program Manager Records

Various HW records must be maintained to document compliance with FGS-I. Those records that 31 CES/CEIE maintains at the 31 CES/CEIE Environmental Office (either electronically or hard copy) are:

TWSA Hazardous Waste Log

• HW Log information required by FGS-I is stored indefinitely using EESOH-MIS, which serves as the official HW Log.

• A separate log of all waste currently stored at the TWSA is made available to emergency personnel in the event of a fire or spill.

• See Section 7.5 for details on how a HW Log is maintained at Aviano AB.

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

Training Records for HWAP Managers

• Maintained in TAB 2 of the HWAP Continuity Binder.

• The 31 CES/CEIE HW Program Manager also keeps electronic copies on file.

• Must be kept for current employees as long as they work at the installation and for an additional 3 years after the date they leave the base (or stop working at a position related to HW management).

HW Turn-In Documents

• HW turn-in documents are created and stored indefinitely using EESOH-MIS and this satisfies the FGS-I requirement to retain for 5 years.

• EESOH-MIS can be used to print DD Form 1348-1A, and Issue Release/Receipt Documents for any current or past HW turn-in events.

HW Manifests (Formulario di Identificazione del Rifuto)

• See Section 7.6 for details on how a HW manifest is completed at Aviano AB.

• Manifests of HW that are transported off-site under Aviano AB’s Waste Registration Number must be retained for 5 years.

• The First Copy and Fourth Copy of the waste manifest must be kept physically together with the

Waste Loading and Unloading Register.

Waste Loading and Unloading Register (Rifiuti Registro di Carico E Scarico)

• See Section 7.6 for details on how a Waste Loading and Unloading Register is maintained at Aviano

AB.

• The register will be retained for 5 years after the date of its last entry.

• Must be kept physically together with the First Copy and Fourth Copy of the waste manifest.

Hazardous Waste Profile Sheets and Waste Analysis/Characterization Records

• Aviano AB utilizes EESOH-MIS to document HWPSs.

• Waste Analysis/Characterization Records are documented in both EESOH-MIS and electronic pdfs or hard copies.

• Waste Analysis/Characterization Records must be retained for 5 years.

o

HW Annual Report (Modello Unico di Dichiarazione [MUD] Ambientale)

• See Section 7.1 for details on how the HW Annual report is completed at Aviano AB.

• No official recordkeeping retention timeframe specified in FGS-I, but Aviano AB has chosen as a best management practice to retain for 5 years.

HWAP Information Tracking Spreadsheet

• See Section 7.5 for details on how a HWAP Information Tracking Spreadsheet is maintained at Aviano AB.

• Document is continually updated and has no recordkeeping retention timeframes.

Spill Reporting

31 FW procedures, as outlined in the Aviano AB HMSPRP require responsible organizations or the Fire Department (FD) to report Class I small incidental spills to the 31 CES/CEIE Environmental Element at DSN 632-5394. For Class II or III spills contact the FD. The FD will contact 31 CES/CEIE so they can determine if the spill should be reported to the respective authorities. For additional, spill reporting information contact the 31 CES/CEIE Spill Program Manager at DSN 632-5394.

7.0 PROCEDURES

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

7.1 Waste Inventory

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

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

Installation Supplement – Waste Inventory

The 31 CES/CEIE HW Program Manager maintains an inventory of all waste streams generated throughout the installation in EESOH- MIS. The 31 CES/CEIE HW Program Manager should be contacted in the event that a current waste inventory for Aviano AB is needed and they will then generate a current report from EESOH-MIS using the steps outlined above.

Hazardous Waste Annual Report (Modello Unico di Dichiarazione [MUD] Ambientale)

The HW Annual Report (“MUD Report”) is an official statement listing quantity and type of waste generated by Aviano AB and disposed of in the previous calendar year. The MUD Report includes solid waste, hazardous waste and medical waste and is required by FGS-I Sections C6.3.2 (HW), C7.3.1.2 (Solid Waste) and C8.3.2.1 (Medical Waste). In accordance with Italian regulations, the MUD Report can only be submitted via an online system with specific formatting requirements and data fields. The electronic submittal of the MUD Report for Aviano AB is due to the Italian Authority (Camera di Commercio Industria Artigianato e Agricoltura di Pordenone - Udine) by April 30th each year. Aviano AB contracts out data gathering and development of the report each year. The 31 CES/CEIE HW Program must support the contractor’s data gathering efforts by providing HW manifests, the Waste Loading and Unloading Register, and any other HW documentation requested for the previous calendar year by 15 January of the following calendar year.

7.2 Waste Identification

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

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

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

Installation Supplement – Waste Identification

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

7.3 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.

Installation Supplement – Container Management

In addition to the container management practices mentioned above, the following precautions should be taken by Aviano AB HWAP and TWSA Managers to prevent container leaks and mishaps:

• Containers used to accumulate HW must meet ADR specifications.

o Only containers that are United Nations (UN) rated for liquids may be used to store liquid HWs.

o Waste aerosols for disposal must be placed into vented containers to prevent a dangerous buildup of pressure.

o Plastic UN rated drums and rigid plastic intermediate bulk containers (IBCs) are only permitted for use for ADR regulated HWs within 5 years from the manufacture date.

• Containers must not be stored or handled in a manner which may cause them to rupture or leak.

o Containers containing liquid wastes must not be filled to more than 90% of capacity.

o Containers must be protected from freezing during cold weather.

o Use a funnel to fill closed head containers.

o Drums with solids will not be stacked more than two high.

o Drums containing flammable liquids will not be stacked.

o Do not stack containers at a HWAP.

• Containers with flammable vapors must be grounded when opening lids or transferring contents.

o Containers of flammable liquids must be grounded when transferring flammable liquids. Use a bonding wire to connect both containers (container flammable liquid is poured from and container flammable liquid is poured into) to prevent sparks caused by the build-up of static electricity.

o To prevent build-up of static electricity in open-top containers with contents that generate a flammable vapor (e.g., used rags with Petroleum, Oils, and Lubricants (POL) residue), these containers must be grounded with a bonding wire when removing lids.

• Drums and other containers must be handled and transported with equipment designed for the task.

o Drum grappler attachments may be purchased for tow motors to securely grab and move containers.

o Secure containers to pallets before moving pallets.

o Use drum carts designed for the types of containers used by your organization to reduce the likelihood of dropping a container during handling.

o Never balance drums on the forks of a forklift or tow motor.

• Drums must be placed on pallets to allow for ease of removal when full and to prevent contact with accumulated precipitation or spilled material.

• Containers holding HW must not be placed on dirt, sand, gravel, or grass surfaces.

7.4. Labeling and Marking

Containers used for the accumulation and transportation of HW must be properly identified with a HW marker and an appropriate hazard class label (flammable, corrosive, etc.) at all times from the start of accumulation to ultimate disposal IAW applicable laws and regulations.

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

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

Installation Supplement – Labeling and Marking

Container Labeling and Marking

To ensure that containers are labeled in accordance with all FGS-I requirements and contain the necessary information for internal tracking and processing, Aviano AB has developed a HW label template which is included in Appendix C – Sample Forms and Templates. The Aviano AB HW Label Template includes the following information in English and Italian:

• The term “HAZARDOUS WASTE”.

• Various statements regarding improper disposal, handling with care and procedures to follow if found abandoned.

• Container Identification Number – A unique 8-digit number for each container using the internal tracking format of YYDDDNNN, where YY is the last two digits of the calendar year, DDD is the Julian date and NNN is a sequential number based on the number of containers assigned that day.

• Waste Description – This is the ADR proper shipping name and must match the text in the HWPS Section 4 “Additional Description” field.

• Waste Classification (i.e., European Waste Code [EWC]).

• Generator Information – Waste Producer, Waste Registration Number, Unit/Office, HWAP

Number, and Building Number.

• Container Weight.

• Storage Date – For Area F HWAPs, the date the container is transferred to the TWSA. For HWAPs outside Area F, the date that arrangements are initiated to ship the container off-site via the DLA- DS contract. For containers filling at TWSA, the Storage Date is the date waste is first placed in container.

The TWSA Manager will label all empty containers that will hold HW using Aviano AB HW Label Template (see Appendix C – Sample Forms and Templates), regardless of whether the container is being filled at an HWAP or at the TWSA. For those containers being filled at HWAPs, it is the HWAP Manager’s responsibility to ensure that the HW label remains legible and attached to the HW container as it is filled.

If the label is damaged, the HWAP Manager must contact the TWSA Manager for a replacement label. As each container is determined full during weekly HWAP monitoring and pickup services, the container ID number, weight and storage date will be annotated on the container label by the TWSA Manager.

FGS-I Section C6.3.9.1.7 requires that all containers holding HW have a label indicating the hazard class of the waste contained. Although not required by ADR until transport off installation, Aviano AB has chosen to have ADR hazard class labels on containers at HWAPs. The decision to place ADR hazardous class labels on containers at HWAPs was made to enhance awareness of hazards and as a means to comply with FGS-I Section C6.3.9.1.7. TWSA Manager must affix to containers placed at HWAPs ADR hazard class labels appropriate to the waste being accumulated at the site. Note that not all HWAP containers hold waste that is regulated by ADR and therefore not all HWAP containers will require hazard class labels.

Additional container labeling may be required before HW is transported on Italian public roads and highways by the DLA-DS contractor to a disposal/treatment facility. One example of this is Italian Legislative Decree 152/2006 (Decreto Legislativo 152/2006) which requires prior to transport that hazardous special waste containers must be affixed with a label or drawn with a 15 cm by 15 cm yellow sign with the letter “R” in black, 10 cm high, 8 cm wide and 1.5 cm wide. It is the responsibility of the DLA-DS contractor to ensure that all containers or packaging originated from Aviano AB containing HW are labeled and marked IAW applicable international and Italian regulations before off-base transportation occurs.

Hazardous Waste Accumulation Point Signage

As a best management practice for ensuring that each HWAP complies with FGS-I signage requirements and communicates the necessary tracking and safety information, Aviano AB has developed a HWAP Identification Sign Template which is included in Appendix C – Sample Forms and Templates. Each Aviano AB HWAP must have an identification sign posted that complies with the HWAP Identification Sign Template found in Appendix C – Sample Forms and Templates.

As another best management practice for ensuring safety at HWAPs, Aviano AB has determined that "No Smoking – Vietato Fumare" signs must be placed conspicuously at all HWAPs where there is a hazard from ignitable or reactive waste.

FGS-I Section C6.3.9.3.1 requires that each HWAP have warning signs (National Fire Protection Association or appropriate international sign) appropriate for the waste being accumulated at that site.

Aviano AB has determined that ADR hazard class labels on individual containers are an appropriate international warning sign. Since HWAP waste streams can change and not all approved HWAP waste streams are necessarily accumulating at any given time, Aviano AB has chosen to have ADR hazard class labels placed directly on applicable HWAP containers (see previous discussion under Container Labeling and Marking section) rather than maintain separate hazard class signage at each HWAP.

The 31 CES/CEIE HW Program Manager should be contacted if assistance is needed to obtain appropriate HWAP signs. It is the responsibility of the HWAP Managers to ensure that all signs are present and clearly visible.

7.5 Hazardous Waste Management

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

HW should not be stored longer than 90 days in a TWSA.

Wastes intended to be recycled or used for energy recovery…