Attachment 5 - HWMP Mildenhall.pdf

U. S. AIR FORCE

OVERSEAS HAZARDOUS WASTE MANAGEMENT PLAN

RAF Mildenhall

DAY MONTH 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 AFIMSC DET 4/CEIE 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 – RAFM HWAP Facility Listing

Appendix C – Emergency Reporting and Information Numbers

Appendix D – Hazardous Waste Storage Area Closure Plan

Appendix E – Sample Forms and Templates

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 Initial XX/XX/2019 100 ARW/CV

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Record of Annual Review – IAW AFMAN 32-7002 Chap 5. Hazardous 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 if no FGS exists, the Overseas Environmental Baseline Guidance Document, AFMAN 32-7002 Chap 5 acts as a main driver for the HWMP. The HW Playbook serves as supplemental guidance to this plan.

Installation Supplement – Overview and Scope

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

Applicability for Royal Air Force Mildenhall (RAFM)

This plan was established to implement an effective and comprehensive HW management program at RAFM while ensuring all tasks are being carried out according to AF, European Union (EU), and Final Governing Standards for the United Kingdom (FGS-UK) requirements and operating procedures.

All US Air Force (USAF) personnel at RAFM, including tenant activities and temporary duty (TDY) personnel, will comply with the responsibilities and procedures stipulated herein, and will support this plan's implementation and update as deemed necessary by the 100 ARW Commander as Chair of the

ESOHC.

Environmental Office, 100 CES/CEIE, Annual Review Procedures

The installation environmental office (100 CES/CEIE) annually conducts an internal review of the HWMP.

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

• Section 2 – Installation Profile

• Section 4 – Roles and Responsibilities

• Section 8 – References

• Appendix B – RAFM HWAP Facility Listing

• Appendix E – Sample Forms and Templates

2.0 INSTALLATION PROFILE

Installation Profile

Scope of Plan All USAF personnel at RAFM, tenant activities, and TDY personnel.

Office of Primary Responsibility

(OPR)

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

HW Program Manager 100 CES/CEIE; 238-5828/5836/4993 Alternate HW Program Manager 100 CES/CEIE; 238-5828/5836/4993 Emergency contacts Fire Department 999 or 911 from a base telephone or 01638 547999 from a mobile phone

Off-Base Emergency 999

Defense Infrastructure Organization Environmental Advisor 226-6679 or 07476 637845

Refer to Appendix C for additional contact information.

Waste registration numbers DLADIS; This is the code used for all UK installations as there is no EPA Registration Number for overseas installations.

FGS regulatory references FGS-UK November 2017 Local regulatory agencies Not applicable Local regulatory references Not applicable Approved HW disposal contractors Defense Logistics Agency - Disposition Services (DLA-DS) HW storage areas Building 820 HW accumulation time limits One year HW generator reporting frequency N/A; this installation is overseas

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

The AF environmental program adheres to the EMS framework and its Plan, Do, Check, Act cycle for ensuring mission success. Executive Order (EO) 13693, Planning for Federal Sustainability in the Next Decade, U.S. Department of Defense Instruction (DoDI) 4715.17, Environmental Management Systems, AFI 32-7001, Environmental Management, and International 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 “Hazardous Waste Storage Area”

(HWSA) Supervisors/Managers

• Unit Commanders

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

• Contracting Officer

• Defense Logistics Agency Disposition Services

• Tenant Organizations

• AFCEC

Detailed information about typical responsibilities for these and other roles is available in AFMAN 32- 7002, 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

100th Air Refueling Wing Commander (100 ARW/CC)

The 100 ARW Commander is ultimately responsible for HW management and compliance and will:

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

• Ensure all enforcement actions are resolved quickly

• Appoints, in writing, primary and alternate Hazardous Waste Program Managers as personnel authorized to sign HW manifests

• Signs HW permit applications or other regulatory binding agreements as required

Environmental, Safety and Occupational Health Council

• Chaired by either 100 ARW/CC or 100 ARW/CV

• Reviews and approves HWMP when substantive changes are made

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

Staff Judge Advocate (100 ARW/JA)

• Evaluates, reviews and ensures proper interpretation of UK environmental laws, US Federal regulations, Status of Forces Agreement, and advises 100 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 (100 ARW/PA)

• Acts as focal point for inquiries from 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 100 CES/CEIE in promoting HW management program through use of available information media

Occupational Safety Office (100 ARW/SEG)

• Reviews the HWSA and HWAPs for safety issues while performing facility safety inspections

• Ensures plans and procedures comply with applicable safety requirements

• Assists in coordination of new HWAP sites

Installation Dangerous Goods Advisor (DGA)

• Ensures Installation Dangerous Goods Program is implemented in accordance with USAFE Instruction (USAFEI) 23-104, and performs all duties listed therein relating to HW

• Acts as a consultant and provides guidance to 100 CES/CEIE on HW movement

• As a management best-practice, coordinates Unit Dangerous Goods Advisor/ADR Certifier class for HW Program Managers appointed to sign HW manifests

Base Civil Engineer (100 CES/CC)

• Assumes management responsibility of environmental program and ensures 100 CES/CEIE has adequate resources to effectively manage HW program

• As a management best practice, assigns primary and alternate HW Program Managers

• Monitors any service contracts for follow-on cleanup and disposal of HW by a contractor

Installation Management Office (100 CES/CEI)

• Consults with tenant units and HW Program Manager to determine HW support requirements during development process of support agreements

Environmental Office (100 CES/CEIE)

• Provides primary and alternate HW Program Managers

• Reports HW program status to ESOHC

Installation Hazardous Waste Program Manager (Primary & Alternate)

• Maintains HWMP and reviews at least annually then presents changes to EMS CFT

• Liaises with AFIMSC DET 4/CEIE for requests for waste management services (WMS) through

DLA-DS

• Monitors DLA-DS contractor performance and reports discrepancies/concerns to contracting officer representative (COR) and AFIMSC DET 4/CEIE

• Implements Waste Analysis Plan (WAP) IAW Appendix A

• Ensures appropriate use of standardized AF HW system, Enterprise Environmental, Safety and

Occupational Health Management Information System (EESOH-MIS)

• Performs CE annual oversight inspections of HWAPs and HWSA IAW Section 7.8

• Provides technical expertise to generating activities regarding waste management

• Ensures funding requirements are properly identified and reported to AFIMSC DET 4/CEIE

• Maintains HWSA records IAW Section 6

• Prepares permit applications, as needed, and coordinates authorization through 100 ARW/CC

• Re-validates HWAP waste streams annually with HWAP managers

Base Fire Department (100 CES/CEF)

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

• Coordinates and approves/disapproves of siting and design of HWAPs and HWSAs under jurisdiction of 100 ARW, IAW applicable fire standards

Bioenvironmental Engineering (100 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

Defense Logistics Agency - Disposition Services (DLA - DS)

• Provides HW disposal contracting and oversight services and guidance

• Provides copies of HW manifests and delivery orders (including modifications) to HW Program

Manager

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

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

• Coordinates HW removal between contractor and HW Program Manager

Logistics Readiness Squadron (LRS) - HAZMART (100 LRS/LGRMSH)

• Manages waste minimization program

• Processes requests for disposition for expired HM in EESOH-MIS

Commanders of Generating Activities

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

• Appoint in writing, to HW Program Manager, a primary and alternate manager for each HWAP (see Appendix E – Sample Forms and Templates)

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

• Provide safe equipment and locations for HWAPs

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

HW

Unit Environmental Coordinator (UEC)

• Ensures HWAP Managers are appointed and properly managing HWAPs IAW their assigned roles and responsibilities

• As a best management practice, for units that produce small amounts of HW and do not warrant a HWAP Manager, the UEC shall receive HW Awareness Training and coordinate HW Awareness Training for their unit personnel as needed

Hazardous Waste Accumulation Point Managers and Alternates

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

• Manage HWAPs IAW HWMP and all applicable policies, regulations, and laws

• Successfully complete annual HWAP Manager training given by HW Program Managers prior to working unsupervised with HW IAW Section 5

• Conduct HW Awareness Training to individuals that handle or have the potential to be exposed to

HW IAW Section 5

• Coordinate with HW Program Manager & 100 CES/CEF on initial location or relocation of

HWAPs Section 7.5

• Ensure proper HW procedures are followed IAW Section 7

• Conduct weekly inspections of their HWAPs IAW Section 7.8

• Maintain a HWAP Continuity Binder IAW Section 6.0

• Notify HW Program Manager when a change in type or quantity of HW generated will occur to ensure contract requirements for disposal can be processed in a timely manner

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

• Maintains HWSA facility and records, Building 820, in compliance with FGS-UK and DLA-DS contractual requirements

• Receives and stores RAFM-generated HW IAW FGS-UK

• Maintains a supply of appropriate empty containers that are uniquely identified for collection of

HW IAW Section 7.3

• Issues containers to HWAPs that are ready to receive HW

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

• Identifies Proper Shipping Name (PSN), Hazard Class, United Nations (UN) number and

Packaging Class for all HW streams to be transported off-site

• Ensures usable HM are processed through LRS HAZMART before being accepted for disposal

• Inspects HWSA weekly IAW Section 7.8

• Coordinates with HW Program Manager weekly to ensure HW log is maintained

5.0 TRAINING

HW awareness training is provided to satisfy AFMAN 32-7002 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

100 CES/CEIE Hazardous Waste Program Manager Training

The HW Program Manager may receive the following trainings:

• WENV 521 - Air Force Institute of Technology (AFIT) Hazardous Waste Management Course.

The refresher training requirement for this course is satisfied by conducting HWAP Manager training or attending USAFE HW refresher training events hosted by AFIMSC DET 4/CEIE

• Unit Dangerous Goods Certifier Training, offered by the Installation Dangerous Goods Advisor, as required in USAFE Instruction 23-104, USAFE Command Dangerous Goods Program. Initial training and annual refresher training are both offered

HWSA Manager Training

The RAFM HWSA Manager is a contractor hired by DLA-DS and, per contractual requirements, are responsible for obtaining any necessary HW training. The HWSA Manager may choose to attend the HWAP Manager training offered by the HW Program Manager as a means of receiving training on all topics required to meet DoD and FGS-UK requirements. However, the responsibility to be fully trained and capable to work as a HWSA Manager ultimately resides upon the contractor.

HWAP Manager Training

The HWAP Manager Training is a classroom session conducted by the HW Program Manager covering all topics required to meet DoD and FGS-UK requirements and RAFM-specific issues. The HW Program Manager will offer initial HWAP Manager training when new HWAP Managers are assigned by the unit commander. Refresher training will be provided by the HW Program Manager.

HW Awareness Training

The HW Awareness Training is conducted by each HWAP Manager for all employees in their unit who work with and/or have the potential to be exposed to HW. A template for HW Awareness Training is maintained by the HW Program Manager and covers all topics required to meet DoD and FGS-UK requirements and RAFM-specific issues. The HW Program Manager will work with each HWAP Manager to update the template with shop-specific information. The HWAP Managers will provide initial HW Awareness Training to personnel with potential HW exposure, prior them working with HW.

Personnel will attend the HW Awareness Training annually as refresher training. As a management best practice, RAFM requires personnel to sign a proof-of-training letter upon completion of HW Awareness Training (see Appendix E – Sample Forms and Templates).

Training Documentation

Training certificates must be kept with HWAP documentation. Completed training must also be documented on the individual’s AF Form 55, Employee Safety and Health Record. Records must be kept for current personnel as long as they work on the installation, and for three years after the date they leave the base (or stop working at a position related to HW management). Shop supervisors will keep the original training records for all personnel. Additionally, the HW Program Manager maintains a centralized record to document successful completion of HW training by HWAP Managers and Alternates.

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 HW determination documentation

3 years from the closure of the HWSA and

HWAP

FGS

HW manifest (turn-in document)

3 years FGS

HWSA logs Until closure of installation FGS Hazardous waste inspection logs

3 years FGS

Employee HW training records

3 years from date of termination of duties FGS

Reporting

The HW Manager, and other designated personnel, generate needed reports from the Enterprise Environmental, Safety and Occupational Health Management Information System (EESOH-MIS).

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

Installation Supplement – Recordkeeping and Reporting

Record Keeping and Reporting Requirements

Each RAFM HWAP will maintain a hard copy or electronic Continuity Binder with the documentation specified below at the following tabs (see Appendix E – Sample Forms and Templates):

TAB 1: HWAP Manager Appointment Letter

TAB 2: HWAP Manager Training Certificates

TAB 3: List of Shop Personnel with HW Awareness Training

TAB 4: RAFM HWMP

TAB 5: Site-Specific Spill Response Plan

TAB 6: HWAP Inspection Log

TAB 7: Summary of Waste Streams

TAB 8: HW Profile Sheets

TAB 9: Safety Data Sheets (SDSs)

TAB 10: Turn-In Documentation (including guidance and examples of documentation)

TAB 11: HW Container Label Template

TAB 12: Miscellaneous Information

Hazardous Waste Storage Area Records

The following records must be maintained by the HWSA Managers (DLA-DS Contractor):

• Internal turn-in documents, from generating activities and HWAPs, turned into HWSA

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

Name/address of generator Description and hazard class of the HW Number and types of containers Quantity of HW Date stored Storage location Disposition data to include: dates received, sealed, transported, and transporter used o The HW Log will be available to emergency personnel in the event of a fire or spill o Log will be maintained until closure or transfer of the installation

• HWSA Weekly Inspection Logs o See Appendix E – Sample Forms and Templates o Records of inspections shall be maintained for a period of 3 years o Deficiencies or problems discovered by the inspection shall be reported to the HW Program

Manager

• Manifests o Manifests of incoming HW Must be retained for a period of 3 years o Manifests of HW that are transported off-site Must be retained for 3 years Manifest will include the following information:

• Generator’s name, address, telephone number, fax and email

• Generator’s unique identification number, as appropriate for the shipment type

• Transporter’s name, address, and telephone number

• Destination name, address, and telephone number

• Description of the waste including the process producing the waste and the Standard Industrial Classification (SIC) for the process giving rise to the waste, typically 75.22 for Defense activities (contact the LEC for a current listing of SIC codes)

Installation Hazardous Waste Program Manager Records

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

• Waste Characterization Records o HWPSs o Sample Analysis Reports

Must be retained until 3 years after closure of the HWSA

• Manifests of HW that are transported off-site under RAFM’s Waste Registration Number

Spill Reporting

100 ARW procedures, as outlined in the 100 ARW HAZMAT Spill Prevention and Response Plan, require responsible organizations to report releases of greater than 110 gallons of POL or any amount of HW releases requiring assistance of the Fire Department or the 100 CES Fuels Spill Response Team (100 CES/FSRT) to the 100 CES/CEIE Spill Program Manager at extension 238-5652.

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 HW Program Manager should be contacted in the event that a current waste stream inventory for RAFM is needed and they will then generate a current report from EESOH-MIS using the steps outlined above.

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 https://cs2.eis.af.mil/sites/10626/Mildenhall/Shared%20Documents/Spill%20Program/100%20ARW%20HAZMAT%20Spill%20Prevention%20and%20Response%20Plan%20(FINAL%202017Mar27).pdf 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 RAFM-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

HWAP Managers may obtain the appropriate empty containers from the HWSA. It is the ultimate responsibility of the HWAP and HWSA Managers to ensure the HW containers are managed according to the requirements described in this section.

• Containers on RAFM must be UN-approved containers

• Containers filled with liquids must not be overfilled (no more than 90% capacity)

• Incompatible waste and materials must not be placed in the same container and must be stored and disposed of separately

• Containers must be protected from freezing

• Containers holding ignitable waste shall not be stacked more than 1 high. Containers holding non-ignitable waste shall not be stacked more than 2 high

• Only intrinsically safe tools or equipment are authorized to be used to open/handle containers holding ignitable materials

• Adequate aisle space must be maintained to allow free movement of personnel, firefighting equipment, and spill prevention materials

• Containers cannot block entry or exit points

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

• Use a funnel to fill closed head containers

• Containers shall be stored in an area that is well protected from damage due to the movement of vehicles such as trucks, forklifts, privately owned vehicles (POVs), etc.

• Containers shall be stored upright

• Waste containers containing fluorescent lamps shall be stored upright or stacked horizontally, as appropriate, on pallets or in appropriately designed storage racks

Secondary Containment

Container storage areas for liquids must have a secondary containment system meeting the following criteria:

• Sufficiently impervious to contain leaks, spills and accumulated precipitation until the collected material is detected and removed

• Capacity to contain 25% of the volume of all stored containers or 110% of the entire volume of the largest container, whichever is the greatest

• Drains for water runoff should be locked in the closed position to prevent inadvertent discharge

• Rainwater collected in secondary containment areas must be visually inspected and/or tested prior to release. Contaminated water should be treated as HW until determined otherwise

Storage areas not intended for liquid wastes do not require secondary containment, provided the area is sloped, contains some way of draining or removing precipitated liquids, and the containers are elevated or otherwise protected from accumulated liquid.

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. The Hazardous Waste marker will include a description of the contents of the container in the form of a Proper Shipping Name (PSN) as established in the waste characterization process and used on the waste manifest which accompanies the container to the ultimate disposal site (either paper or approved electronic form).

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

The HWAP Manager or generator is responsible for marking and labeling all containers at the start of accumulation. HW must be collected in properly labeled containers, as outlined in the FGS, Chapter 6.

Warning signs on labels have to be compliant with the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation and the GHS (Globally Harmonized System).

Contractor-provided containers may be picked up from the HWSA. UN-approved, user-owned containers must also be labeled. Containers or packaging containing HW that are offered for off-base transportation must be labeled and marked IAW ADR, CLP/GHS (EC 1272/2008) and 2000/532/EC (European Waste Catalog). The ADR shipping label is provided by contractor at the day of shipment.

The HW-Label must include the following information:

• HWAP number

• Waste Stream number

• Hazardous Waste Profile Sheet number

• Words “Hazardous Waste” (or a UK Hazardous Waste Label)

• PSN of the Waste

• UN Number

• Point-of-contact and 24-hour phone number

• GHS Hazard Class Warning Label

• Description of waste

• Transportation diamonds with appropriate class markings for the HW

See Appendix E – Sample Forms and Templates.

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 HWSA or ship it off-site for treatment or disposal.

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

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

Installation Supplement – Accumulation Point Management

Each HWAP/HWSA must meet the criteria outlined in FGS-UK, Chapter 6 Hazardous Waste.

Hazardous Waste Accumulation Point Operating Procedures

All HWAPs are operated according to the following standards:

• HWAP must be at or near point of generation

• HWAP must be under control of operator

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

• Small amounts of HW that are generated at multiple areas serviced by a single HWAP (i.e., in shop bays) are transferred to designated HWAP or HWSA on a daily basis

• Closure inspection by HW Program Manager

Hazardous Waste Generators

All other shops that generate HW but do not have a HWAP must turn HW in directly to the HWSA as soon as possible.

Hazardous Waste Storage Area Operating Procedures

The HWSA is operated according to the following standards:

• HWSA must be designed, constructed, maintained, and operated to minimize possibility of a fire, explosion, or any unplanned release of HW or HW constituents to air, soil, groundwater, or surface water that could threaten human health or environment

• “Danger Unauthorized Personnel Keep Out” signs are posted at each entrance to the HWSA and at other locations, in sufficient numbers to be seen from any approach to HW site. Signs are legible from a distance of at least 25 feet. Existing signs with a legend other than “Danger Unauthorized Personnel Keep Out,” are used when the legend on the sign indicates that only authorized personnel are allowed to enter HWSA and entry to it can be dangerous

• “No smoking” signs are posted at HWSA that are used for storage of flammable substances. Signs are maintained to be clearly visible and legible

• Whenever HW is being poured, mixed or otherwise handled, personnel involved in operations have immediate access to an internal alarm or emergency communication device, either directly or through visual or voice contact with another person

• Portable fire extinguishers, water at adequate volume and pressure, spill-control equipment, decontamination equipment, and PPE are readily available

• HWSAs may have more than one container of a particular waste stream

• HW is not stored longer than one year

• HWSA is secured against unauthorized access by a fence, which is maintained in good repair and completely surrounds the HWSA. Access at entrance point is controlled 24/7 with a locked gate

Hazardous Waste Accumulation Point Authorization

If a work center at RAFM desires to either create a new HWAP or move an existing HWAP, the generating unit or HWAP Manager should complete and forward a request letter to the HW Program Manager. As a management best practice at RAFM, once the request has been validated by the HW Program Manager, the memorandum will be coordinated with the Fire Department (CEF), Wing Occupational Safety (SEG), 48 AMDS/SGPB Bioenvironmental for formal approval and authorization. A template memorandum for establishing new HWAP is included in Appendix E – Sample Forms and Templates. Work centers requiring to add or alter a new waste stream to an existing HWAP must made the request to the HW Program Manager.

Hazardous Waste Accumulation Point Closure/Clean-up

Closure/clean-up of all HWAPs must be accomplished prior to departure of tenants or rotation of HW site management personnel. Closure/clean-up includes the following:

• Proper disposal of all waste on hand or transfer to incoming units

• Cleanup of any spilled HW in the area

• Restoration of the site to original condition

• Turn-in of all loaned equipment and supplies

• Closure inspection completed by HW Program Manager and if applicable, Installation Restoration

Program Manager

Hazardous Waste Storage Area Closure Plan

See Appendix D

7.6 Transportation

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

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

• Containers are approved.

• Transporters have the appropriate training.

• Uniform Hazardous Waste Manifest are prepared for offsite transportation.

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

Installation Supplement – Transportation

On-Base Transportation of HW

Movement of the HW to the HWSA at Building 820, is the responsibility of the generating activity and should only be carried out by personnel who are trained to do so and must comply with the RAFM Supplement to the USAFEI23-104.

Off-Installation Transport of HW

All Air Force owned HW from RAFM will be collected by the DLA-DS contracted waste management company and transferred to a waste treatment or disposal facility. The licensed carrier will comply with current regulations to include the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR), the Joint Regulation for the Safe Movement of Hazardous Goods via Surface Modes (USAFEI23-104, USAFE Command Dangerous Goods Program), and the RAFM Supplement to USAFEI23-104.

In certain instances, waste is transported directly from HWAPs to Treatment, Storage, and Disposal Facilities. This situation is most common in the case of non-appropriated fund activities and contract activities on base (e.g. construction and demolition projects or AAFES/DECA). In these instances, the disposal contractor is responsible for supplying all necessary paperwork and shipping documents. The HWSA Manager will receive copies of all paperwork and will track the HW shipments as described above. All other requirements of this plan apply.

7.7 Turn In/Disposal

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

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

Installation Supplement – Turn In/Disposal

Hazardous Waste Turn-In from HWAP to HWSA

Once a HW container holding liquid has reached 90% capacity or a HW container holding solids has reached 100% capacity, it must be turned into the HWSA within 5 days. The HWSA will accept HW

Turn-In/Disposals Monday through Friday from 1:00 pm to 4:00 pm. Generators or generating activities shall comply with the following procedures prior to coordinating transfer of HWs from a HWAP to the

HWSA:

• Properly containerize and label HW

• Review the HWPS for accuracy and currency

• Complete RAFM’s Turn-In Document (see Appendix E – Sample Forms and Templates) for turn-in along with the HW

• Containers must be handled in such a way as to not place the container in danger of rupturing, dropping, spilling, or splitting

After transportation of the HW to the HWSA

• The HW will not be accepted until the HWSA Manager inspects HW to ensure it matches description provided on container label and HWPS

• Reject turn-ins that do not match the accompanying waste descriptions unless the generator provides an accurate description

• If the generator cannot clearly identify the HW unknown items will remain at the HWSA marked with “Pending Analysis” (see Appendix A, WAP)

• HWSA Manager logs HW received onto Hazardous Waste Log and emails copy of Turn-In Document to HW Program Manager

• HW Program Manager creates containers in EESOH-MIS (parent-child)

Hazardous Waste Storage Area Disposal

• HW Program Manager processes removal orders in EESOH-MIS and coordinates with DLA-DS contractor and to schedule pickup

• On day of pickup, all 3 agencies must be present: DLA-DS, HW Program Manager, and DLA- DS contractor, to verify correct declaration of labeling/loading/weighing of HW. Once correct, HW Program Manager can sign HW manifest

• DLA-DS sends removal order modifications to HW Program Manager for corrections on final weights in EESOH-MIS

• HW manifests are sent to HW Program Manager for recordkeeping

• Delivery order is closed in EESOH-MIS by HW Program Manager

7.8 Inspection

Inspection processes fulfill the “Check” function of the EMS “Plan, Do, Check, Act” cycle. HWSA are inspected routinely IAW the FGS to ensure proper accumulation and container management. All other inspections occur IAW AFI 90-201, The Air Force Inspection System and the Commander’s Self Inspection Program. Inspection records are maintained IAW the Recordkeeping and Reporting section of this plan.

Installation Supplement – Inspection

Hazardous Waste Storage Area Inspections

• The HWSA Manager must inspect the HWSA weekly using “HWSA Weekly Inspection Checklist” included in Appendix E – Sample Forms and Templates

• Areas subject to spills, such as loading/ unloading areas, must also be inspected daily when in use

• Deficiencies or problems discovered during inspection shall be corrected immediately by HWSA

Manager

Hazardous Waste Accumulation Point Inspections

• As a best management practice, HWAP Managers must conduct weekly inspections of their HWAPs using the “HWAP Inspection Checklist” included in Appendix E – Sample Forms and Templates

• As a best management practice, HWAP Managers must document weekly inspection within TAB 6 of the HWAP Continuity Binder

CE Annual Oversight Inspections

• HW Program Manager will perform environmental compliance assessments IAW AFI 90-201, Air Force Inspection System, and AFI 32-7001, Environmental Management

• HW Program Manager will also conduct no-notice inspections of HWSA and each HWAP at least once per year to verify compliance using “HWAP Weekly Inspection Checklist” and “HWSA Weekly Inspection Checklist” included in Appendix E – Sample Forms and Templates

• HW Program Manager will review the annual inspections as recorded in TAB 6 of the HWAP Continuity Binder and will also provide the results of the oversight inspection to be included in TAB 6 of the HWAP Continuity Binder

• As part of annual HWSA oversight inspection, HW Program Manager will review HWSA’s weekly inspection forms on file for past twelve months and will also provide results of oversight inspection to be included in HWSA inspection records

7.9 Waste Minimization

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

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

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

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

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

Installation Supplement – Waste Minimization

RAFM utilizes an EMS to manage its environmental program, including the HW program. This system emphasizes education and continual improvement, which includes the focus on pollution prevention, source reduction, and the RAFM Free Issue Program. All AF HW Managers are trained on pollution prevention and encouraged to communicate any ideas for further HW reductions to the HW Program Manager.

7.10 Preparedness and Prevention

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

Installation Supplement – Preparedness and Prevention

It is the policy of RAFM to prevent spills wherever possible and to respond effectively when they do occur.

Please refer to the 100 ARW HAZMAT Spill Prevention and Response Plan, for specific spill preparedness and prevention requirements and procedures to be followed.

Site-specific contingency plans must be developed and maintained at each HWAP/HWSA and by HW Program Manager. As a management best-practice, once modified to reflect site-specific operations, a copy of the plan must be permanently posted at the HWAP or HWSA. The plan must be conspicuously located and readily available for inspection. Site personnel must be:

• Aware of contents and required actions outlined in contingency plan

• Trained and prepared to implement contingency plan when an emergency occurs

The site-specific contingency plan must include, at a minimum, the following:

• General information on the facility covered by the plan including the organization name, building number, HWAP number, and HWAP Manager’s name

• An inventory of the types and quantities of HWs stored at the accumulation point

• Emergency contact information

• A list of emergency equipment (fire extinguisher, spill kits, communications and alarm systems, and PPE) and the physical location of the equipment within the facility

• Description of immediate response and notification actions that should be taken when a spill is first discovered to included containment, cleanup, and disposal procedures

7.11 Waste Specific Procedures

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

Installation Supplement – Waste Specific Procedures

Unused Product Turn-ins

All unused products that are also hazardous materials and excess to the using activities’ needs will be turned in for disposal only after the HAZMART (100 LRS/LGRMH) has determined that the material(s) is unsuitable for re-issue or re-use (See Appendix E – Sample Forms and Templates).

Waste Oil Turn-ins https://cs2.eis.af.mil/sites/10626/Mildenhall/Shared%20Documents/Spill%20Program/100%20ARW%20HAZMAT%20Spill%20Prevention%20and%20Response%20Plan%20(FINAL%202017Mar27).pdf

Waste oil will be accepted at the waste oil facility, Building 1585. Turn-ins can be made on Wednesdays from 10:00 am to 11:00 am. In exceptional circumstances, turn-ins must be coordinated with the HWSA Manager. A completed HWPS must accompany all waste oil turn-ins if one has not been previously completed.