Attachment 5 - WMP Lakenheath.pdf

48th FIGHTER WING (USAFE)

Hazardous Waste Management Plan

June 2020

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 hazardous waste management program manager and/or the Air Force Installation and Mission Support Center – Detachment 4, Environmental Section (AFIMSC Det 4/CEIE) support appointed to support this installation.

This document is optimized to be accessed and viewed electronically on the installation and Air Force 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 GENERAL 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

Appendix A – Waste Analysis Plan

Appendix B – Information and Emergency Contacts

Appendix C – RAF Lakenheath HWSA Closure Plan

Appendix D – RAF Lakenheath and RAF Feltwell HWAP Facility Listing

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’s Office of Primary Responsibility (OPR).

Record of Updates

Change No. Nature of Change Date of Change Approved By:

0 Standardization of

HWMP

3/17/2017 R Webb

1 Standardization of Appendix A

3/7/2019 R Webb

2 Change to record keeping

7/12/2019 R Webb

3 Updated to latest standardized template and comprehensively updated all installation-specific sections and appendices.

11/22/2019 R Webb

4 AFMAN 32-7002

supersedes

AFI 32-7086

AFI 32-7042

3/31/2020 R Webb

5 Administrative changes, i.e. grammar and syntax.

5/12/2020 R Webb

6 Administrative changes to E1 HWAP Inspection Sheet

10/21/2020 R Webb

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Record of Annual Review – In accordance with (IAW) AFMAN 32-7002, 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)

4/5/2018 ECFT No Changes YES 4/4/2019 ECFT Standardization of

Appendix A

YES

6/8/2020 ECFT Approved at ECFT YES

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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, acts as a main driver for the HWMP. The HW Playbook serves as supplemental guidance to this plan.

Installation Supplement – Overview and Scope

Purpose

This plan serves as primary guidance for managing HW activities at Royal Air Force (RAF) Lakenheath and RAF Feltwell. It provides a management overview and specific requirements for the successful execution of the HW program. If there is a conflict between this plan and regulatory guidance, the regulatory requirements will take precedence. This plan is intended to assist operators, technicians and managers in meeting 48 FW HW program requirements. The cooperative efforts of many organizations and individuals are required for effective implementation of the 48 FW HW program.

Overview

This HWMP establishes the overall strategy, delineates responsibilities, and sets forth specific objectives for effective management of HW at RAF Lakenheath and RAF Feltwell. Effective HW management requires active, continuing participation at all levels of management. This plan supports AF directives and is intended to ensure compliance with the applicable Final Governing Standards for the United Kingdom (FGS-UK), DoD, and AF requirements.

Environmental Office, 48 Civil Engineer Squadron (CES)/CEIE, Annual Review Procedures

The installation environmental office, 48 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 – General Roles and Responsibilities

• Section 8 – References

• Appendix D – RAF Lakenheath and RAF Feltwell HWAP Facility Listing

Guidance

AFMAN Waste Management provides AF HW management guidance, which requires each installation to develop a plan outlining an overall program strategy. This plan satisfies those requirements.

• Hazardous Communication (HAZCOM). This plan does not discuss requirements for the hazardous communication program. LAKI 90-802, Workplace Hazard Communication Program, defines the requirements for the HAZCOM program.

• Hazardous Materials (HAZMAT) Management. HAZMAT requirements are covered in AFMAN 32-7002, HAZMAT Management is not covered in this plan.

• Hazardous Materials Spill Prevention and Response Plan. This HWMP does not describe the actions and reporting requirements for spills or releases of HAZMAT. That information is found in the 48 FW 32-4013 Hazardous Materials Spill Prevention and Response Plan.

Legal Considerations

The objectives, policies and procedures included within this plan are in effect when approved by the 48 FW ESOHC chairperson, responsible for implementing AF environmental policy at RAF Lakenheath and RAF Feltwell. This plan may direct management requirements that are more stringent than regulations. If a conflict arises between this plan and regulatory requirements, such as the FGS-UK, regulatory requirements take precedence.

Final Governing Standards. The FGS-UK, 2017, provides specific standards for environmental protection at DoD installations in the United Kingdom (UK). The standard’s requirements are included in the Overseas Environmental Baseline Guidance Document (OEBGD), DoD Instruction (DODI) 4715.5, Management of Environmental Compliance at Overseas Installations and Executive Order (EO) 12088, Federal Compliance with Pollution Control Standards.

• The FGS-UK C6.3.3.3.1 requires that a waste analysis plan (WAP) is developed to determine how and when wastes are analyzed. This requirement is satisfied in Appendix A of this plan.

2.0 INSTALLATION PROFILE

Installation Profile

Scope of Plan This plan is designed to define processes related to the HW management program at RAF Lakenheath and RAF Feltwell.

Office of Primary Responsibility

(OPR)

48 CES/CEIE at DSN 226-3990 has overall responsibility for implementing the HW management program and is the lead organization for monitoring compliance with regulations

HW Program Manager Rebecca Webb: rebecca.webb.2.gb@us.af.mil

DSN: 314-226-3989

Alternate HW Program Manager

Kylene Lang: kylene.lang.1@us.af.mil

DSN: 314-226-5985

Emergency contacts Fire Department - 911 Emergency Medical Care – 911 Refer to Appendix B for additional contacts

Waste registration numbers RAF Lakenheath - Feltwell DLA-DS. DLA-DS is the code used for all UK installations as there is no EPA Registration Number for overseas installations

FGS regulatory references FGS-UK, Chapter 6 Local regulatory agencies Defence Infrastructure Organization/Environment Agency

Local regulatory references Not Applicable

Approved HW disposal contractors

Defense Logistics Agency Disposition Services (DLA-DS)

HW storage areas Building 1218, RAF Lakenheath HW accumulation time limits No time limits during accumulation at HWAP; 1 year at HWSA HW generator reporting frequency

Not Applicable mailto:rebecca.webb.2.gb@us.af.mil mailto:kylene.lang.1@us.af.mil

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. EO 13693, Planning for Federal Sustainability in the Next Decade, U.S. 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 instilling a culture of continuous improvement. The HWMP serves as an administrative operational control that defines compliance-related activities and processes.

4.0 GENERAL ROLES AND RESPONSIBILITIES

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

• Wing/Installation Commander

• ESOHC

• HW Program Manager/Alternate

• Shop/HW Generator Personnel

• 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 (DLA-DS)

• 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 – General Roles and Responsibilities

Specific responsibilities for organizations and personnel tasked with HW program management and implementation are described in the following paragraphs.

Installation Commander – 48 FW/CC

• Be responsible for compliance with the FGS-UK and regulations applicable to HW.

• Sign, or delegate in writing, the authority to sign HW consignment notes. Signature delegation shall remain with active duty and AF civilian employees only.

• Ensure that HAZMAT is made available for reuse to the maximum extent possible before disposal.

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

Environmental, Safety and Occupational Health Council (ESOHC)

• Chaired by 48 MSG/DC.

• Direct matters involving HW management.

• Review HW management procedures as needed and resolve any conflicts or areas of noncompliance.

• Reviews and approves HWMP when substantive changes are proposed.

Environmental Management System Cross Functional Team (EMS CFT)

• Reviews HWMP, at least annually, with administrative changes annotated in the plan by the 48 CES/CEIE HW Program Manager, without need for ESOHC approval.

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

Civil Engineer Squadron – 48 CES/CC

• Assign, equip and train sufficient personnel to support the implementation of this plan by the OPR, 48 CES/CEIE.

• Ensure contractors working on behalf of RAF Lakenheath and RAF Feltwell Civil Engineer (CE) projects comply with all necessary requirements for the collection and disposal of HW.

Installation Management Flight, Environmental Management Element – 48 CES/CEIE

• Establish local procedures, prepare and maintain management plans and provide technical expertise with regard to waste management requirements and preparation of a Hazardous Waste Profile Sheet (HWPS) for transport and disposal of HW.

• Review HWPS using information provided by the waste generator, Safety Data Sheet (SDS) and analytical results, if applicable.

• Maintain a copy of each HWPS IAW retention times prescribed by the Air Force Records Disposition Schedule.

• Develop and submit five-year budget requests for facilities, personnel, training, and other waste management needs.

• Oversee proper programming and record keeping procedures.

• Prepare, review and update the WAP IAW Appendix A.

• Provide sampling and analysis of HW as necessary for proper characterization, management and disposal.

• Complete HW reporting requirements as necessary, including submittals for data calls.

• Coordinates and supervises the HW training for all RAF Lakenheath and RAF Feltwell personnel

IAW Section 5.0.

• Provide technical assistance for generators for MICT Stage 1 SAC assessments as needed.

• Manage the HWSA.

• Prepare waste shipping documents in coordination with DLA-DS.

• Participate in approval of HWAP and HWSA locations.

• Liaises with AFIMSC DET 4/CEIE for requests of 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.

• 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 6.0.

• Re-validates HWAP waste streams annually by evaluating the shops’ HWPS.

Fire Protection Flight – 48 CES/CEF

• Provide guidance, technical expertise and assistance to implement this plan.

• Participate in approval of HWAP and HWSA locations.

Installation Dangerous Goods Advisor – 48 MSG/IDGA

• Provide advice for the safe transport of HW from or within RAF Lakenheath and RAF Feltwell.

• Coordinate Dangerous Goods Certifier training for those 48 CES/CEIE personnel designated to sign HW consignment notes.

• Advise the generator on completion of the proper shipping information, containers and transportation requirements in the HWPS.

Contracting Squadron – 48 CONS

• Provide contracting support and expertise for all contracts that either generate or require the disposal and movement of waste.

• Provide timely and effective contracting support to 48 CES/CEIE to accomplish HW management, as appropriate, including using applicable provisions of the Federal Acquisition Regulation (FAR) and environmental policies and procedures.

Bioenvironmental Engineering (BE) Flight – 48 AMDS/SGPB

• Advise the generator on completion of the health portions of the HWPS, on request.

• As requested, participate in approval of HWAP and HWSA locations.

• Provide environmental and occupational health consultation services IAW AFI 48-145, Occupational and Environmental Health Program.

Safety – 48 FW/SE

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

• Ensure plans and procedures comply with applicable safety requirements.

• As requested, participate in approval of HWAP and HWSA locations.

Judge Advocate – 48 FW/JA

• Identify applicable HW management laws, regulations, EOs and policies for the ESOHC.

• Provide advice to ensure compliance and provide legal support at hearings.

Plans and Programs – 48 FW/XP

• Consult with tenant unit and 48 CES/CEIE to determine tenant unit HW support requirements during development of Support Agreements (SA).

• Define requirements and responsibilities in SA.

Work-Area Supervisors of HW Generating Activities

• Manage HW and HWAP IAW the FGS-UK and this plan in coordination with 48 CES/CEIE.

• Ensure a primary and alternate HWAP monitor is assigned by the shop supervisor. Appointments must be documented electronically by e-mail to the 48 CES/CEIE HW Program Manager.

• Attend HW management training, both initial and annual refresher IAW Section 5.0.

• Ensure all personnel that are assigned duties involving actual or potential exposure to HW are trained IAW Section 5.0.

• Coordinate with 48 CES/CEIE to characterize (i.e. to determine whether or not they are hazardous) all wastes and prepare HWPS.

• Ensure that all new and existing waste streams and/or process changes have been coordinated with

48 CES/CEIE, 48 CES/CEF, 48 FW/SE and 48 AMDS/SGPB.

• Notify HWSA personnel when HW containers are full to schedule pickup.

• Ensure requirements for proper HW management, such as labeling and disposal, are implemented

• Maintain documentation and recordkeeping IAW this HWMP.

• Notify 48 CES/CEIE of unknown wastes.

• Ensure shops have an adequate supply of materials and equipment to accommodate routine collection of HW and any potential emergency situations (i.e. spill kits).

• Prepare and update a Site Specific Spill Plan and ensure all personnel are trained on spill prevention and response procedures.

• Support and implement HW minimization or pollution prevention initiatives directed by the 48 FW

ESOHC.

• Minimize HW generation to the maximum extent possible by following the HAZMAT management procedures of AFMAN 32-7002.

Hazardous Waste Accumulation Point (HWAP) Monitors and Alternates

The HWAP Monitors and Alternates are appointed by their supervisor. The supervisor will email the 48 CES/CEIE HW Program Manager to update the training/appointment tracker. All generators of HW must be capable of recognizing, tracking and maintaining all documentation necessary for proper HW management. The HWAP Monitors and Alternates main duties include:

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

• Successfully complete annual RAF Lakenheath Hazardous Waste Monitor Training given by 48

CES/CEIE HW Program Managers prior to working unsupervised with HW IAW Section 5.0.

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

HW IAW Section 5.0.

• Coordinate with 48 CES/CEIE HW Program Manager, 48 CES/CEF, and 48 FW/SE on initial location or relocation of HWAPs IAW Section 7.5.

• Ensure proper HW procedures are followed IAW Section 7.0.

• Conduct weekly inspections of their HWAPs IAW Section 7.8.

• Notify 48 CES/CEIE 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.

Unit Environmental Coordinator (UEC)

• Attend HW management training as required by 48 CES/CEIE.

• Assist HW monitors, supervisors, and unit staff with staying in compliance with this plan.

Tenant Organizations

• Comply with all requirements of the FGS-UK and this HWMP, unless exempted by DoD/AF Instructions.

• HW support for tenant organizations will be defined in the tenant organization Support Agreements.

Defense Logistics Agency Disposition Services (DLA-DS)

• Provide HW disposal contracting and oversight services. Provides copies of HW manifests and delivery orders (including modifications) to 48 CES/CEIE 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 48 CES/CEIE HW Program Manager.

Defence Infrastructure Organization (DIO) (formerly Defence Estates)

Defence Infrastructure Organization consigns and tracks wastes generated through their contracts on behalf of the U.S. Visiting Forces.

• Defence Infrastructure Organization assigns their own consignment note code numbers for shipments and tracks those shipments on a separate database from the 48 FW HW shipments.

• Defence Infrastructure Organization retains copies of the consignment notes for three (3) years, per UK requirements.

• Each year, DIO renews the site HW registration for RAF Lakenheath and RAF Feltwell by 14 July and provides this number to 48 CES/CEIE.

5.0 TRAINING

Hazardous Waste 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. Hazardous Waste 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

Installation Hazardous Waste Program Manager Training

The 48 CES/CEIE HW Program Manager will complete the following training:

• New HW Program Managers will complete 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 RAF Lakenheath Hazardous Waste Monitor Training or attending USAFE HW refresher training events hosted by

AFIMSC Det 4/CEIE.

• European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR)

Certifier training in order to certify HW shipments leaving the installation (initial with annual refresher).

Hazardous Waste Accumulation Point (HWAP) Monitors and Shop Personnel Training

In accordance with FGS-UK C6.3.9.1, personnel and their supervisors assigned to duties involving actual or potential exposure to HW must successfully complete an appropriate training program prior to assuming those duties. These tasks include generation, movement, handling or characterization.

• Hazardous Waste Accumulation Point Monitors (primary and alternates) and shop supervisors must attend the RAF Lakenheath Hazardous Waste Monitor Training. This training is administered in person by the 48 CES/CEIE HW Program Manager.

• Shop-level worker training is developed by the HWAP Monitors and supervisors for their particular shop. A training template is provided by 48 CES/CEIE outlining the required information and is available on the 48 CES/CEIE eDASH SharePoint website. This document should be kept electronically and updated for correctness on a yearly basis or if a new waste stream is introduced into the shop. As long as the template is followed, 48 CES/CEIE does not need to approve the training slides. Any deviation from the template requires approval.

• In accordance with FGS-UK C6.3.9.2, refresher training is accomplished annually for Shop Level Workers and HWAP Monitors.

• After the HWAP Monitor delivers the training, a record of all shop personnel trained will be kept.

A training record template is available on the 48 CES/CEIE eDASH SharePoint page. Shops will send the tracker to the 48 CES/CEIE HW Program Manager on the first week of July each year, where it will be kept for three years.

• Only the 48 CES/CEIE HW Program Manager can approve alternative training to satisfy FGS-UK requirements.

• Training records must be maintained for as long as personnel are present at the site and at least three (3) years after termination of HW duties at the site.

Hazardous Waste Storage Area (HWSA) Personnel Training

Individuals’ assigned duties at the HWSA will complete the following training:

• RAF Lakenheath Hazardous Waste Monitor Training (annually)

• Dangerous Goods Certifier Training (initial with annual refresher)

Shipment Personnel Training

Individuals who sign consignment notes on behalf of 48 FW should be ADR certified and designated by the Wing Commander.

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-UK

Section C6.3.5.6

HW manifest (turn-in document)

3 years FGS-UK Section C6.3.5.1

HWSA logs Until closure of installation FGS-UK Section C6.3.5.3

Hazardous waste inspection logs

3 years FGS-UK Section C6.3.5.4

Employee HW training records

3 years from date of termination of duties FGS-UK Section C6.3.9.4

Reporting

The 48 CES/CEIE HW Program Manager, and other designated personnel, generate needed reports from EESOH-MIS (Enterprise Environmental Safety Occupational Health-Management Information system).

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 (HWAP) Recordkeeping Requirements

Hazardous Waste Accumulation Points are required to maintain the following records, either hard copy or electronic.

Site-Specific Spill Plan. Each HWAP must have a site specific spill plan that addresses spill procedures at that location and is formatted IAW 48 CES/CEIE requirements. The 48 CES/CEIE Spill Manager will review the plan for completeness. The plan must contain an accurate site map that includes at a minimum the locations of HWAP and HAZMAT storage lockers, drain locations, spill kits, fire extinguishers, eyewash stations and Personal Protective Equipment (PPE).

Spill Reporting Procedure. Refer to 48 FW 32-4013, Section 4.2.8. Spill Cleanup, Storage, and Disposal, Section 4.2.9. Post Spill Incident Response, and 4.3. Industrial Discharge (Slug) Response Procedures located on eDASH at the following link:

https://cs2.eis.af.mil/sites/10626/Lakenheath/WPP/ProgramPage/Hazardous%20Waste.aspx.

Hazardous Waste Storage Area (HWSA) Documentation Requirements

• Hazardous Waste Storage Area Log. Recordkeeping of all HW containers picked up, transported to the HWSA, and shipped offsite for disposal is maintained in EESOH-MIS and available at any time by using the system’s reporting features. This information will be maintained until closure of the installation.

o A written log (electronic) 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;

https://cs2.eis.af.mil/sites/10626/Lakenheath/WPP/ProgramPage/Hazardous%20Waste.aspx

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.

• Weekly Inspections. The HWSA must be inspected at least every seven days to include containers and equipment on site – see Appendix E – Sample Forms and Templates. Inspection logs are maintained by 48 CES/CEIE on site, and maintained for three (3) years.

• Hazardous Waste Storage Area Contingency Plan. The contingency plan details emergency procedures and maintained by 48 CES/CEIE on site.

• Hazardous Waste Storage Area Closure Plan. A closure plan will be maintained for the HWSA by 48 CES/CEIE. It is located at Appendix C.

• Hazardous Waste Tracking System (electronic) o EESOH-MIS is the standardized Air Force HW tracking & reporting system. EESOH-

MIS functions will be maintained to provide for:

Real time tracking of every container issued by the HWSA Site lists, waste stream lists, and waste codes HW and waste oil processed through the HWSA, by organization, quantity, and type

48 CES/CEIE will maintain program plans, documents, and templates referenced in this section on the RAF Lakenheath environmental eDASH website at the link below:

https://cs2.eis.af.mil/sites/10626/Lakenheath/WPP/ProgramPage/Hazardous%20Waste.aspx

Training Documentation

Proper documentation is essential to an effective training program. Section 5.0 Training defines training requirements for the HW program. 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.

Training records for HWAP Monitors and shop personnel and training records for HWSA personnel are kept at the 48 CES/CEIE office. Additionally, the 48 CES/CEIE HW Program Manager maintains a spreadsheet tracking the appointment of HWAP Monitors and their most recent training completion dates.

Training records for the 48 CES/CEIE HW Program Manager must be kept in the 48 CES/CEIE Environmental Office files. Training records must be kept for current employees as long as they work at the installation and for an additional three (3) years after the date they leave the base (or stop working at a position related to HW management).

Reporting Spill Reporting 48 FW procedures, as outlined in the Spill Prevention and Response Plan, require responsible organizations to report releases of any amount of HW releases to the 48 CES/CEIE Environmental Office at 226-3990 and to the Fire Department.

7.0 PROCEDURES

This section contains procedures for managing HW from identification, accumulation, offsite transportation and disposal. The 48 CES/CEIE HW Program Manager ensures that appropriate procedures are properly communicated and followed by all necessary personnel.

7.1 Waste Inventory

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

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

Installation Supplement – Waste Inventory

The HWSA Manager or 48 CES/CEIE HW Program Manager should be contacted in the event that a current waste inventory for RAF Lakenheath or RAF Feltwell is needed and they will then generate a current report from EESOH-MIS using the steps outlined above.

Hazardous Waste (HW) Stream

A HW stream is defined as HW that has the same properties that allow it to be shipped off-base under the same information. Each waste stream is assigned a HWPS number.

Hazardous Waste Accumulation Point Monitors or shop supervisors must immediately contact the 48 CES/CEIE HW Program Manager when potentially generating a new waste stream. See Appendix E – Sample Forms and Templates for the Hazardous Waste Stream Review Request form.

7.2 Waste Identification

The 48 CES/CEIE HW Program Manager determines the nature of waste based on a detailed qualitative analysis of the regulated waste generating process, associated SDS information, and coordination with generating activity personnel involved in the use of HAZMAT. If uncertainties about a waste stream exist, the 48 CES/CEIE HW Program Manager pursues waste stream sampling and analysis IAW the 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 RAF Lakenheath-specific waste identification procedures.

7.3 Container Management

Container management procedures are as follows:

• Containers storing HW must be in good condition and meet permit, 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

Hazardous Waste Accumulation Point Monitors 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 Section 7.3, Container Management.

The following precautions should be taken at HWAPs and the HWSA to prevent container ruptures and leaks:

• Containers must not be overfilled. A minimum 6-inch gap will be maintained to allow for expansion and for drum movement.

• Closed head containers must be filled using a funnel.

• Drums must not be stacked more than two high. Drums containing flammable liquids must not be stacked.

• Containers should be stored in an area, which is away from or protected from damage due to the movement of vehicles such as trucks, forklifts, etc.

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

• Containers must remain closed at all times, except when waste is added or removed. Closed means that for open-top drums, the lid is securely closed using the clip or nut and bolt on the drum ring.

For closed-top drums, the bung cap is in place and tightened. For drums accumulating liquids that are filled through a funnel, the funnel must be closed unless adding fluids.

Secondary Containment

Container storage areas must have a secondary containment system meeting the following requirements:

• If HW liquids are accumulated, they must be kept on secondary containment spill pallets both indoors and outdoors.

• Containment must be monitored for spills and the spillage removed when it is identified.

• Containment must be adequately sized to hold 25% of the volume of stored containers or 110% of the volume of the largest container, whichever is greater.

• Separate containment is required for incompatible hazards.

Hazardous Waste Storage Area (HWSA)

Container Management

• 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.

• Containers must be segregated by appropriate hazards.

• Storage bays must be appropriately marked with the HW in storage.

7.4. Labeling and Marking

Containers used for the accumulation and transportation of HW must be properly identified with a Hazardous Waste 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 road and highways, HW generators will prepare off-installation HW shipments in compliance with DoD Component Policies. Requirements may include placarding, marking, containerization, and labeling. Hazardous Waste designated for international transport will be prepared in accordance with the documents listed above and applicable international regulations.

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

Installation Supplement – Labeling and Marking

Hazardous Waste Accumulation Points (HWAPs)

Labels

Every active HW container at an HWAP must have a correct and complete HW label.

• Labels are generated and provided by the HWSA and are delivered with containers to the HWAPs.

• The HWAPs are responsible for maintaining the label on each container.

• The HWAPs must contact 48 CES/CEIE immediately if a container is missing the required label.

• Labels must be securely adhered to the container and placed so that they are clearly visible at all times upon approach to the HWAP and to anyone placing waste in the container.

• Labeling information must remain legible at all times.

Placards

Placards or hazard diamonds are required for items that have a PSN and are regulated for transport on the roadways.

• The HWSA will provide the HWAPs with the appropriate hazard diamond sticker for each container.

• The HWAPs are responsible for maintaining the hazard diamond sticker on each container.

• The HWAPs must contact 48 CES/CEIE immediately if a container is missing the required hazard diamond.

• The hazard diamond should be placed near the HW label on the container and should be visible upon approach to the HWAP.

7.5 Hazardous Waste Management

An 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 (5) working days to move the HW to an HWSA or ship it off-site for treatment or disposal.

Hazardous waste should not be stored longer than one (1) year in an 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 (1) year.

Installation Supplement – Hazardous Waste Management

Hazardous Waste Accumulation Point Operating Procedures The HWAP Monitor and Alternate assume overall responsibility for management of the HWAP. Details on the overall management of the HWAP are outlined in Section 4.0, Roles and Responsibilities of the HWAP Manager and Alternate.

The previously discussed waste identification (Section 7.2), container management and containment requirements (Section 7.3) and labeling and marking (Section 7.4) also apply to HWAP operations.

Furthermore, there are additional record keeping and reporting requirements (Section 6.0) relevant to HWAP operations also previously discussed. Other specific requirements for HWAPs are listed below:

• The HWAP must be at or near the point of generation.

• The HWAP must be under the control of the unit managing it. Authorized site security measures include constant monitoring, a locked storage unit, or locked containers.

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

• Each HWAP is required to have a portable fire extinguisher and an emergency eyewash station, PPE, and a spill kit with adequate materials for the type of HW stored. The spill kit must contain an adequate amount of appropriate spill materials for items accumulated on site or any potential spill from facility operations. For example, if corrosive liquid is accumulated on site, spill absorbents made for corrosives must be present. The purchase of spill kits and materials is the responsibility of the user.

• Signage for the HWAP must be visible from 25 ft. Information on the sign must be kept updated.

The HWAP sign should include the HWAP assigned number, the HWAP shop’s phone number, and the emergency phone number.

• The HWAP Monitor submits requests to the HWSA Manager via telephone at DSN 226-5352 to pick up full containers and should expect containers to be collected within five working days. The HWSA Manager will replace the full containers with empty containers that are labeled to accept the same waste as the full container.

Establishment of HWAPs

Any organization on base that determines its activities will generate HW must contact 48 CES/CEIE to establish an HWAP in advance of waste generation.

• The operator must contact 48 CES/CEIE and 48 CES/CEF to allow these offices an opportunity to inspect the proposed HWAP location. 48 AMDS/SGPB and 48 FW/SEG will be notified of new or changed HWAP locations.

• HWAP monitors or supervisors must notify the offices listed above if moving an accumulation point or a waste stream.

• Each waste-generating functional area shall appoint a primary and alternate site manager for each HWAP and/or accumulation site.

• All HW must be within the control of a responsible, trained party. The waste must be placed into the appropriate HWAP container in a timely manner, but no later than the end of the shift.

Hazardous Waste Storage Area Operating Procedures

The only HWSA for RAF Lakenheath and RAF Feltwell is located at Building 1218, RAF Lakenheath. The previously discussed waste identification (Section 7.2), container management requirements (Section 7.3) and labeling and marking (Section 7.4) all apply to HWSA operations as well as record keeping requirements (Section 6.0). There are other more rigorous requirements for HWSAs as listed below:

• Communications. An internal communications or alarm system capable of providing immediate emergency instructions (voice or signal) to HWSA personnel must be available. The HWSA is currently equipped with a fire alarm system and a telephone.

• Emergency Equipment. Portable fire extinguishers, fire control equipment appropriate to the material in storage, spill control equipment and decontamination equipment must be available on site.

• Water Supply. Water with adequate volume and pressure must be available on site.

• Eyewash and Shower. Eyewash and shower facilities must be on site.

• Personnel Protective Equipment. An adequate amount of PPE of the appropriate size and type must be readily available.

• Security. The facility entrance gate at the HWSA is kept locked when personnel are not present.

The HWSA consists of lockable units. Any unit storing HW must be locked when not in use.

• Signage. “Danger Unauthorized Personnel Keep Out” signs must be posted at each entrance to the HWSA and visible from at least 25 feet.

• "No Smoking" signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste.

• If there is only one person on duty at the HWSA premises, that person must have immediate access to a device, such as a telephone (immediately available at the scene of operation) or a hand held two way radio, capable of summoning external emergency assistance.

Hazardous Waste Storage Area Closure Plan

A closure plan has been developed for the RAF Lakenheath HWSA (Appendix C). The closure plan will be implemented in the future if a decision is ever made to close the HWSA at Building 1218.

7.6 Transportation

The 48 CES/CEIE HW Program Manager has overall responsibility for the transportation of HW from an HWAP to an HWSA, and from an HWSA to the disposal facility. The 48 CES/CEIE 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 Manifests 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

Hazardous Waste (HW) Transport from RAF Feltwell to RAF Lakenheath HWSA

Hazardous wastes should never be transported from RAF Feltwell to RAF Lakenheath. Generation of HW at RAF Feltwell should be coordinated with 48 CES/CEIE to establish an HWAP and ensure proper storage.

48 CES/CEIE will coordinate pickups and shipments of HW from RAF Feltwell with DLA-DS and an authorized HW transporter.

7.7 Turn In/Disposal

The turn-in procedures are 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 Accumulation Points (HWAPs)

Turn-In and Disposal from HWAPs

All HAZMAT and HW are removed to the HWSA on a pick-up basis by HWSA personnel.

• To schedule a removal, contact the HWSA at 226-5352 or the 48 CES/CEIE HW Program Manager at 226-3990. The full container will be removed within five working days.

• HWAP Monitors must be aware of the status of their drums and schedule pick-ups accordingly.

• Proper documentation must be provided at the time of waste removal. A profile number for recurring waste streams or an SDS for expired or unusable HAZMAT must be provided.

• Unknown items will remain at the HWAP marked with ‘pending analysis’ and the date the sample was taken until sample results are returned and the waste is properly characterized. The procedures in Appendix A must be followed to request a HW review of unknown items.

• HWAPs must ensure maximum reuse of HAZMAT prior to disposal.

Hazardous Waste Storage Area (HWSA) Disposal

• 48 CES/CEIE HW Program Manager processes removal orders in EESOH-MIS, coordinates with DLA-DS contractor, and schedules pickup.

• On day of pickup, all three (3) agencies must be present: DLA-DS, 48 CES/CEIE HW Program Manager, and DLA-DS contractor, to verify correct declaration of labeling/loading/weighing of HW. Once correct, 48 CES/CEIE HW Program Manager can sign the HW manifest.

• DLA-DS sends removal order modifications to 48 CES/CEIE HW Program Manager for corrections on final weights in EESOH-MIS.

• HW manifests are sent to 48 CES/CEIE HW Program Manager for recordkeeping.

• Delivery order is closed in EESOH-MIS by 48 CES/CEIE HW Program Manager.

Empty Hazardous Materials (HAZMAT) Containers

• Empty HAZMAT containers may be eligible for recycling if the container contains less than 1% product (or 0.1% of an acute HW) and the container no longer retains any hazardous properties.

• Some products, because of their nature and tube-like packaging, such as sealants and adhesives, are unlikely to meet the above requirements to qualify as empty.

• If unsure whether a container meets the requirements identified above, contact 48 CES/CEIE for additional information.

• If empty containers are to be recycled and meet the requirements listed above, they may be turned in to the Recycling Center, Building 1140 during operating hours.

Illegal Dumping

Illegal dumping, also called fly-tipping or midnight dumping, is letting waste out of your control by depositing it outside of allowable areas. The only allowable areas for industrial HW accumulation or storage are the established HWAPs and HWSA. Waste must be accepted by personnel working at the HWAP or HWSA.

If you witness someone leaving HW at the HWSA or placing HW in a regular trash dumpster, contact 48 SFS at DSN 226-4631.

Waste Removal by Contractors Outside of DLA Process

Additional requirements apply to units that choose a HW disposal route other than the HWSA (e.g. Safety Kleen parts washer).

• Any HW removal from RAF Lakenheath or RAF Feltwell must be accompanied by a unique consignment note that should be provided by the HW transporter. Contact 48 CES/CEIE before the scheduled waste removal to ensure the shipment has the correct information for the consignment note.

• Individuals signing consignment notes must have completed appropriate training as an ADR Certifier and provide training certificate to the 48 CES/CEIE HW Program Manager.

• The original consignment note must be…