Attachment 7 - USAG Bavaria HWMP.pdf

US ARMY GARRISON BAVARIA

HAZARDOUS WASTE DISPOSAL

GUIDE

Garmisch-Partenkirchen Military Community Tower Barracks, Grafenwoehr

Rose Barracks, Vilseck Field Camps

Grafenwoehr Training Area

Update January 2020

Scope: This guide supports tenant and training units at Tower Barracks, Rose Barracks and the Garmisch Military Community to comply with German and U.S. Environmental Laws and Regulations pertaining to the disposal of hazardous waste.

USAG Bavaria

Hazardous Waste Disposal Guide – Version 6.0

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TABLE OF CONTENTS

Page

INTRODUCTION ............................................................................................................................................ VII

REVISION HISTORY ..................................................................................................................................... VII

1 FACILITIES FOR STORING AND/OR DISPOSING HAZARDOUS WASTE

1.1 HAZARDOUS WASTE ACCUMULATION POINTS

1.2 (CENTRAL) HAZARDOUS WASTE STORAGE AREAS

1.3 GENERAL INFORMATION

2 HAZARDOUS WASTE DISPOSAL CONTRACT

2.1 CONTRACT MANAGEMENT SERVICES AT HAZARDOUS WASTE ACCUMULATION POINTS (HWAP)

2.2 PROCEDURE AT PICKUP POINTS

2.3 HW AUDIT TRAIL

2.4 HW CONTRACT ON-SITE TECHNICIANS

2.5 WASTE STREAMS INCLUDED IN HW DISPOSAL CONTRACT

2.6 EXCEPTIONS TO THE HW CONTRACT

2.6.1 Compressed Gas Cylinders

2.6.2 Contaminated Soil Storage

2.6.3 CBRN Equipment

2.6.4 Overpacking of Unserviceable Hazardous Materials

3 GENERAL RULES FOR HAZARDOUS WASTE GENERATORS

3.1 RESPONSIBILITIES

3.2 RECORDS

3.3 TRAINING

4 HAZARDOUS WASTE AUDIT TRAIL

4.1 BASIC INFORMATION

4.1.1 Legal Requirements

4.1.2 Definition - What is the Internal HW Audit Trail?

4.1.3 Why Maintain a HW Audit Trail?

HAZARDOUS WASTE AUDIT TRAIL WORKFLOW

4.2 PROCEDURE FOR TRAINING UNITS

5 HOUSEHOLD-TYPE HAZARDOUS WASTE AND WASTE ELECTRONICS

6 TONER RECYCLING AND DISPOSAL MANAGEMENT

6.1 COLLECTION

6.2 HOW TO TURN-IN USED TONER AND INK CARTRIDGES

6.3 TONER HAZARDOUS WASTE TURN-IN

6.4 RECYCLE POST-PAID LABELS

6.5 TONER MANAGEMENT PROGRAM AT LRC/USAG BAVARIA

FIGURES

FIGURE 4-1: HW AUDIT TRAIL WORKFLOW

FIGURE A3-1: HAZARDOUS WASTE PROFILE SHEET

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TABLES

TABLE A1-1: MANAGEMENT SERVICE POINTS – ROSE BARRACKS (VILSECK)

TABLE A1-2: PICKUP POINTS – ROSE BARRACKS (VILSECK)

TABLE A1-3: MANAGEMENT SERVICE POINTS– TOWER BARRACKS

TABLE A1-4: PICKUP POINTS – TOWER BARRACKS

TABLE A1-5: PICKUP POINTS – GARMISCH MILITARY COMMUNITY

TABLE A1-6: PICKUP POINTS – GARMISCH MILITARY COMMUNITY

TABLE A2-7: HW COLLECTION AND DISPOSAL

ANNEXES

Annex 1: Listing of Collection Points / Pickup Points Annex 2: Instructions for Waste Collection and Separation Annex 3: Documents required for Hazardous Waste Audit Trail

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ACRONYMS

AAFES Army & Air Force Exchange Service

ABCT Airborne Brigade Combat Team

AER Army in Europe Regulation

AFSB Army Field Support Brigade

AR Army Regulation

ASP Container for solid HW

AST Aboveground Storage Tank

BASOPS Base Operations Support

Bldg. Building

CARC Chemical Agent Reactive Coating cbm cubic meters

CBRN Chemical, Biological, Radiological, and Nuclear

CLIN Contract Line Item Number

COR Contracting Officer's Representative

DD Department of Defense

DLA Defense Logistics Agency

DO Delivery Order

DOL Directorate of Logistics

DPW Directorate of Public Works

EAS European Activity Set

EO Environmental Officer

FGS-G Final Governing Standards Germany

GTA Grafenwoehr Training Area

HM Hazardous Materials

HMRC Hazardous Material Reuse Center

HN Host Nation

HW Hazardous Waste

HWAP Hazardous Waste Accumulation Point

HWPS Hazardous Waste Profile Sheet

HWSA Hazardous Waste Storage Area

JEAP Joint Equipment Assessment Program

KrWG Kreislaufwirtschaftsgesetz (German Closed Substance Cycle Waste Management Act) l liter

MP Motor Park

MWR Morale, Welfare and Recreation

NSN National Stock Number

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OST On-Site Technician

POC Point of Contact

POL Petroleum, Oil, Lubricants

PPE Personal Protective Equipment

RSSA Regional Supply Support Activity

SAK Supply Activity

SDS Safety Data Sheets

SOP Standing Operating Procedure

SPO Support Operations

TBD To Be Determined

TP Tank Park

UEMCS Utility Energy Monitoring and Control System

USAG United States Army Garrison

UST Underground Storage Tank

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INTRODUCTION

Hazardous waste must be handled, stored, and disposed of in compliance with the Final Governing Standards for Germany (FGS-G), Chapter 6. This Hazardous Waste Management Plan addresses policies and procedures for the proper handling and disposal of hazardous waste at U.S. Army Garrisons (USAGs) Grafenwoehr and Garmisch.

This disposal guide summarizes the Hazardous Waste Management Plan for USAG Bavaria, to include Tower Barracks, Rose Barracks and the Garmisch Military Community, and provides guidance to units generating Hazardous Waste (HW). The following topics are covered by this guide:

• Facilities for the disposal of hazardous waste (Chapter 1);

• HW disposal contract (Chapter 2);

• General rules for hazardous waste generators (Chapter 3);

• Hazardous Waste Audit Trail (Chapter 4);

• Household-type hazardous waste and waste electronics (Chapter 5).

Note that this guide is subject to change due to changes in applicable laws and regulations. Errors and omissions excepted. Contact the Environmental Division, Ms. Fremuth at DSN: 475-7209 (Tower Barracks), Ms. Prem at DSN: 476-2932 (Rose Barracks) or Mr Klumpp at DSN: 440-3838 (Garmisch) for further information on HW segregation and disposal.

REVISION HISTORY

Version No. Date Reviewed Description of Changes Name

1.0 November2010 Revision of table A2-7 Elisabeth Prem

2.0 August 2012 New HW Contract Elisabeth Prem

3.0 March 2013 Adding new pickup point Elisabeth Prem

4.0 November 2013 Change Garrison designation Caecilia Meier

5.0 February 2016 Complete update and reformatting Corina Habermann

6.0 December 2019 Revision of telephone numbers and

pickup points, update of internal audit trail

Elisabeth Prem

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1 FACILITIES FOR STORING AND/OR DISPOSING HAZARDOUS

WASTE

1.1 Hazardous Waste Accumulation Points

Hazardous Waste Accumulation Points (HWAPs) are temporary HW storage areas at or near the point of generation (e.g. motor pool or maintenance facility). They are under the control of the operator. When full, a container can only be stored at the HWAP for 5 days. After that, it must be moved to a Hazardous Waste Storage Area (HWSA) or transported off-post for treatment and/or disposal.

There are 174 HWAPs within USAG Bavaria Tower Barracks, located at Motor Parks (MP), Tank Parks (TP), inside the cantonment area, in field camps, maintenance areas, and firing ranges.

At Rose Barracks (Vilseck) HWAPs/HM Storage facilities have three separate compartments and each one is equipped with catch basin and chemical resistant coating. In addition, several blue hazardous material storage containers are available for the storage of Hazardous Materials (HM).

In Garmisch HW can be stored at the Department of Public Works (DPW); or Base Operations Support (BASOPS) collection points.

Types of HW that shall be stored in HWAPs:

• Oily substances, i.e. contaminated Petroleum, Oil, Lubricants (POL) products, empty metal oil cans, used absorbent, oily rags, filters, brake fluid, lubricants, and grease; Used batteries from maintenance areas (lithium, magnesium, nickel-cadmium, alkaline).

Note: red containers or blue battery drums have been placed throughout the garrison for the disposal of dry cell and alkaline batteries (motor pools, workplaces, and barracks); do not mix with other types of batteries or refuse.

• Hazardous liquids, such as contaminated fuel, antifreeze, paint, alcohols, solvents, acids, and bases.

Make sure all storage compatibility criteria for above mentioned waste streams are met.

1.2 (Central) Hazardous Waste Storage Areas

HWSAs are used for HW collection and storage prior to off-post shipment for treatment/disposal. HW can be stored at the HWSA for up to 1 year. There is one such facility located within USAG Bavaria:

Tower Barracks (Grafenwoehr):

The Tower Barracks Central Hazardous Waste Accumulation Point is located at the former Sanitary Landfill across from Range 118. Operating hours are Monday thru Friday from 0800 – 1200 hours, and from 1300

– 1530 hours. Closed on Wednesday afternoons, and German holidays - open on U.S. holidays. Landfill personnel will provide instructions on where to dispose of what kind of HW.

Rose Barracks (Vilseck):

The DPW Central Hazardous Waste Storage Area at Building (Bldg.) # 124 is located next to the entrance of the Regional Supply Support Activity (RSSA) warehouse. Contact the DPW Environmental Division at DSN 599-4012 to schedule an appointment for the turn-in of hazardous wastes that are not collected at the HWAPs.

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Garmisch:

Garmisch has a central Hazardous Waste Accumulation Point located next to Bldg. # 257. This facility is locked at all times. Contact DPW or Mr. Klumpp at DNS: 440-3838 to obtain access.

1.3 General Information

If you need the support of the HW contractor, you may also call or email your request to the Garrison Environmental Division, Mrs. Prem DSN: 476-2932, elisabeth.a.prem.ln@mail.mil (Rose Barracks) or Mrs.

Fremuth DSN: 475-7209, christine.fremuth.ln@mail.mil (Tower Barracks). Your message will then be forwarded to the HW On-Site Technicians (OST), who will get back with you as soon as possible.

Excess, still serviceable HM will not be accepted at the HWSA, instead it will be turned in at the LRC Hazardous Material Reuse Center (HMRC) (Rose Barracks, Bldg. # 121). Contact the LRC HMRC team at 476-2512 or 475-2605 for guidance.

NOTE:

The LRC HMRC may assist you also to extend the shelf life of your HM.

Disposal fees for expired HM must be paid for by the generator! Provide your MILSBILS and Fund Code to DPW Environmental Division when requesting disposal of expired HM.

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2 HAZARDOUS WASTE DISPOSAL CONTRACT

The Defense Logistics Agency – Disposition Services (DLA-DS) has set up a contract for the direct removal of hazardous waste, which is based on German Waste Disposal Laws and requires strict adherence. This waste disposal contract distinguishes between “management service locations” and “pickup points”. The difference between the two will be explained further in the following chapters. Refer to Annex 1 for a complete listing of pickup points and collection points throughout USAG Bavaria.

2.1 Contract Management Services at Hazardous Waste Accumulation Points (HWAP)

Management Service Locations are regularly serviced by the disposal contractor, who visits each HWAP on a regular basis (currently once a week) to check filling levels of containers and remove waste. USAG Bavaria has scheduled “Contract Management Services” for:

• 15 management locations at Rose Barracks (Vilseck);

• 18 management locations at Tower Barracks (Grafenwoehr); and

• 2 management locations at Garmisch Military Community.

. The HW contractor performs the following services under “contracted management services”:

• Managing HWAPs;

• Preparing and processing of waste disposal documentation;

• Providing appropriate containers (to include proper labeling) which have been approved by the competent German authority;

• Providing sufficient collection capability at collection points at all times;

• Maintaining an inventory at each site, updating it as changes occur and posting it at the collection points for each type of waste;

• Coordinating removal of hazardous waste with the Contracting Officer's Representative (COR);

• Packaging, labeling, and transporting hazardous waste to the final disposal facilities;

• Informing the garrison Environmental Division about any non-compliance at the HWAPs. The HW manager within the Environmental Division will then contact the respective unit Environmental Officer (EO) and inform him/her about non-compliances with HW segregation and collection requirements. If, after three notices, non-compliance persists, the Environmental Division will elevate this issue through the chain of command.

NOTE:

• The generator is still responsible for proper segregation of wastes;

• If the contractor fails to comply with above listed services, the facility/unit EO shall contact the garrison Environmental Division immediately so that deficiencies can be corrected.

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2.2 Procedure at Pickup Points

Pickup points are generally located throughout the Grafenwoehr Training Area (GTA) and Field Camps and at all locations that do not generate waste on a regular basis or generate only small quantities of hazardous waste EOs will call the DPW Environmental Division and request pickups when containers) are ¾ full or will fill up within the following two weeks. ED will inform the contractor and ensure the waste is picked up.

DLA_DS will then establish a Delivery Order (DO) for pickup. After receipt of the DO, the contractor has 21 calendar days to perform the pickup.

• A complete list of management points serviced is attached as Appendix 1. All other listed locations are so-called pickup points

The main collection point for all segregated HW is located at the HWSA. All HW collected in containers less than 1000 l are taken to the HWSA for intermediate storage before final disposal, or whenever containers are full. Empty containers must be returned to the HWAP.

2.3 HW Audit Trail

The hazardous waste audit trail must be observed for all pick-ups at collection points and pickup points, and the EO must sign the “Internal HW Audit Trail Form” ensuring that HW is properly segregated and collected.

Refer to Chapter 4 Hazardous Waste Audit Trail for a detailed workflow.

2.4 HW Contract On-Site Technicians

HW Contract OSTs responsible for Tower Barrack, Rose Barracks, and Garmisch are Mr. Percy, Mr. Levent and Mr. Schmidt from the company Suedmuell. A message for the OSTs may be left with the DPW Environmental Staff at DSN (314) 599-4012, email: elisabeth.a.prem.ln@mail.mil (Rose Barracks); DSN:

475-7209, email: christine.fremuth.ln@mail.mil (Tower Barracks); or DSN: 440-3838, email:

florian.klumpp2.ln@mail.mil (Garmisch). Requests will be forwarded to the OST.

2.5 Waste Streams included in HW Disposal Contract

The DLA hazardous waste disposal contract provides for direct removal. The following waste streams are included in the direct removal contract for hazardous waste at USAG Bavaria, and are picked up from the HWAP at your motor pool:

• Used oil (pumped from underground tank at motor pool or HW shed

• Contaminated fuel;

• POL contaminated solids (empty plastic oil cans, oily rags, POL contaminated absorbent);

• Empty metal or plastic oil cans (up to 5 gal size);

• Oil filters;

• Antifreeze (ethylene glycol);

• Dry cell batteries;

• Lithium batteries.

• Aerosol Cans

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All other types of waste can be picked up at the HWAP by the contractor or can be taken to the Sanitary Landfill (Tower Barracks). Refer to Annex 2 for a complete list of waste streams included in the contract.

Each of the hazardous waste streams must be collected and disposed of separately. If you are unsure how to separate certain hazardous wastes and for disposal information on items not listed here, please contact Ms. Prem from the DPW Environmental Division on Rose Barracks at DSN: (314) 599-4012 or email:

elisabeth.a.prem.ln@mail.mil; or Ms Fremuth from the Environmental Division on Tower Barracks at DSN:

475-7209 or email: christine.fremuth.ln@mail.mil.

The contractor must provide properly labeled containers for the collection of the hazardous wastes. These containers must meet the requirements for the storage of hazardous substances in accordance with the following German regulations: the Ordinance on Hazardous Substances (Gefahrstoffverordnung); the Technical Rules for Flammable Liquids (Technische Regeln für brennbare Flüssigkeiten); and the Water Resources Act, (Wasserhaushaltsgesetz).

HW and HM shall be transported in accordance with the Ordinance on the Transportation of Dangerous Goods on Public Roads (Gefahrgutverordnung Straße) and the ADR (Accord européen relatif au transport international des marchandises Dangereuses par Route – United Nations treaty that governs transnational transport of hazardous materials).

If there is reason to believe that the provided containers do not comply with above-mentioned requirements, please inform the DPW Environmental Division.

2.6 Exceptions to the HW Contract

2.6.1 Compressed Gas Cylinders

Follow the procedures outlined in Army Regulation (AR) 700-68 for handling and return of gas cylinders. If you have gas cylinders to be replaced or returned, please contact the HMRC team at DSN: 476-2512 for information DLA Gas Cylinder Program and support, or contact the DLA E/A Point of Contact WSR Graf/ Hohenfels (Bavaria, GE) under DSN: (314)-581-2469

For details please see: https://www.dla.mil/Aviation/Offers/Products/Commodities.aspx, look for “Industrial Gas Support Program for Europe”.:

Refer to the Tenant Unit Standing Operating Procedure (SOP), Tab G: Compressed Gas Cylinders, for further details on general gas cylinder management.

2.6.2 Contaminated Soil Storage

Soil contaminated with POL shall not be disposed of into the POL Solids container. Instead, follow the procedure outlined below:

• Before any contaminated soil is removed, contact the DPW Environmental Division to receive approval for soil removal and for detailed disposal instructions;

• At Rose Barracks, contaminated soil shall be taken to the central storage area for contaminated soil in Tower Barracks;

• At Tower Barracks contaminated soil shall be transported to the central storage area for contaminated soil near Bldg. # 456. This storage area is fenced and locked. The key can be obtained from the DPW Environmental Division at DSN: 475-7209 (Tower Barracks) during duty hours (0730 – 1600 hrs.) and – in case of emergency – from the Fire Department;

• Make sure that no absorbent material is mixed in with the soil;

https://www.dla.mil/Aviation/Offers/Products/Commodities.aspx

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• Keep in mind that even small quantities of soil are very heavy, and there is no forklift or other equipment available at the soil storage area for unloading and emptying;

• Separately dispose of any containers used for transportation (drums, bags, cardboard boxes etc.).

If uncontaminated and not reusable, place into the respective waste containers at the recycling center. If contaminated, take them back with you and dispose of them in the respective HW container at your motor pool.

2.6.3 CBRN Equipment

All unserviceable Chemical, Biological, Radiological, and Nuclear (CBRN) equipment needs to be processed through the JEFS Program). Please contact the responsible item managers at the 21st Support Operations (SPO). usarmy.rheinland-pfalz.21-tsc.list.dl-21st-tsc-spo-cdet@mail.mil. Or contact Supply Activity Kaiserslautern (SAK), Mr. Kretschmer, DSN: 483-8278.

If you have serviceable CBRN equipment, please contact DLA. Serviceable property MUST stay within the SUPPLY SYSTEM and not turned in as Serviceable Excess unless you have a waiver in writing from the SAK or JEAP Program manager (STAFF).

JEFS Program

JPEO CBD Enterprise Fielding and Surveillance Directorate (JEFS) is the responsible DoD component for dispositions and demilitarization of all Chemical, Biological, Radiological and Nuclear Defense (CBRN-D) Individual Protective Equipment (IPE), also known as NBC equipment. This service is managed by the JEFS Defense Accountability Reutilization and Disposal (DARD) activity. The JEFS has three areas of services for IPE, disposal/demilitarization, reutilization of Code “A” and training assets.

See also: https://www.dla.mil/DispositionServices/Offers/Disposal/DEMIL/jefs.aspx

To Request Disposition/Disposal send completed form DD1348-1 to smblogcomjeap@usmc.mil.

mailto:usarmy.rheinland-pfalz.21-tsc.list.dl-21st-tsc-spo-cdet@mail.mil

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2.6.4 Overpacking of Unserviceable Hazardous Materials

The procedures mentioned below need to be followed for HM turn-in or the disposal of unserviceable HM.

Requesting overpacks: Requests for plastic drums (overpacks), which shall be on hand at each HWAP in case of emergency, should be directed to the RSSA, Bldg. # 113 on Rose Barracks. Provide a Department of Defense (DD) Form 2765 and request a "Drum, PE, 120 l" or a "Drum, PE, 60 l". You may also order directly by using your International Merchant Purchase Authorization Card (IMPAC) card. The Environmental Division has catalogues of different companies offering environmental protection equipment such as HM storage containers, Personal Protective Equipment (PPE) etc.

How to use overpacks:

• Read the Safety Data Sheet (SDS) for the product to be overpacked. Insure that the manufacturer’s name on the SDS matches the name of the manufacturer on the product;

• Obtain the proper PPE as indicated on the SDS. If unsure what the substance is, contact the DPW Environmental Division for help in obtaining a lab analysis;

• Keep all other supplies on hand and ready to use: absorbent; plastic sheeting; drip pan; overpack drum; decontaminating material (water, liquid soap, sodium bicarbonate, etc.); non-sparking shovel, dust pan, broom; etc. You may also need pallets and a forklifts;

• The following instructions are for non-leaking substances only:

o Inventory the property you are overpacking. Write down the National Stock Number (NSN), name of item, quantity, size of cans, and manufacturer’s name. Read the SDS before you start;

o If the substance is non-leaking, but severely dented, corroded and fragile, put on the required PPE in case the product breaks and spills. Refer to your SOP for spill cleanup;

o Remove locking ring and lid from the drum. Place the drum on a plastic sheeting, pallet, or in a drip pan;

o Place two (2) inches of absorbent in the drum;

o Place cans gently into the drum;

o Add just enough absorbent to soak up the liquid if all the cans were leaking. At a maximum just enough to cover the cans. Remember that the cost of disposal is by weight;

o Place the lid on the drum. Add the locking ring and lock down tight.

• Using a permanent marker, mark each overpack drum with the NSN, name of product, quantity inside and manufacturer’s name.

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2.6.5 Special Instructions for Lithium Batteries

• Lithium Batteries

• Keep lithium batteries away from water and humidity. Do not use water-based fire extinguishers!

• Lithium batteries must be vented prior to transportation or turn-in.

• a. Always follow the instructions (warning label)

• on the battery or packaging!

• b. Remove strip/tag completely and/or depress button until click is heard. Some lithium batteries (Li-SO2) have a LED as Complete Discharge Device (CDD) indicator!

• c. Discharge in well ventilated area for at least 5 days!

• d. Make sure all batteries are placed at

• least 2 inches (5 cm) apart in all directions!

• All lithium batteries must be protected against external short circuiting!

• a. Tape the exposed contacts or place the battery in a small individual plastic bag or cardboard box (e.g. original packaging)!

• b. Short circuited batteries develop extreme heat!

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3 GENERAL RULES FOR HAZARDOUS WASTE GENERATORS

3.1 Responsibilities

HW generators have the following responsibilities:

• Sort and segregate waste and do not place any waste on the ground. Contractor personnel will check HWAPs routinely and inform the Environmental Division about any issues concerning improper waste segregation;

• Ensure personnel utilizing the HWAP understand the operating procedures;

• Ensure proper use of secondary containment to prevent spills;

• Ensure that a sufficient quantity of over pack drums, absorbent material and PPE (as indicated on the SDS) are on-hand when storing and handling HM;

• Attend all HW removals and container deliveries (see Chapter 4 for details);

• Keep outside storage containers (e.g. 10 cubic meter container for POL contaminated solids) closed at all times to protect the contents against rainwater! Remember that the cost of disposal is by weight;

• Do not mix different types of hazardous wastes or regular refuse with hazardous waste. Keep HWAPs clean and free of spills. Note: Soda cans are not considered hazardous waste, but are often found in containers for the collection of empty metal oil cans;

• Dispose of all HW generated within your area of responsibility at the designated HWAP or turn in to the Central HWSA at Bldg. # 124 (Rose Barracks) or at the Sanitary Landfill (Tower Barracks).

Make sure to place HW into the proper containers. The contractor will not pick up HW found at locations other than at the designated collection points;

• Prepare a HW Profile Sheet (Annex 3, Fig A3.1) for each HW created by the military unit or civilian organization

• Turn excess or expired but still serviceable HM in at the HMRC, Bldg. # 121 on Rose Barracks.

Note that only unopened containers will be accepted!

3.2 Records

The following HW records shall be retained:

• Inspection Logs: 3 yrs.

• HW Log: Until closure

• HW Register: 3 yrs. from last entry

• Training Records: 3 yrs. from termination

• Turn-in Documents: 3 yrs.

• Internal HW audit trail: 3 yrs.

3.3 Training

All personnel involved in HW handling, storage, and disposal must receive training before assuming work duties involving HW exposure, and annually thereafter. This shall enable them to properly describe the waste and ensure container contents correspond with the HW Profile Sheet (HWPS) and the label on the HW collection containers.

Verbal operating instructions are given to all employees prior to initiating work with HW.

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4 HAZARDOUS WASTE AUDIT TRAIL

4.1 Basic Information

4.1.1 Legal Requirements

• Army in Europe Regulation (AER) 200-1 Section 6-4 b;

• Department of Defense Instruction (DODI) 4715.5;

• FGS-G, July 2017; Chapter C6.3.1.4.3 Audit Trail: The FGS apply to “actions of Department of Defense (DoD) components at installations located in the Federal Republic of Germany”, and have been approved by the United States European Command (USEUCOM). The FGS-G states that “Generators will maintain an audit trail of HW from the point of generation to disposal.”

4.1.2 Definition - What is the Internal HW Audit Trail?

• HW must be controlled from the point of generation until final disposal. Each HW generator must be able to certify the proper collection, segregation, classification and labelling of the waste; The generating activity/unit completes and signs Internal HW Audit Trail (Fig. A3-2) and provides it to the HW Manager before or during the actual removal (if necessary, the Environmental Division will assist with completing the form)

• According to AER 200-1, Chapter 6-4, c(b) USAG Bavaria will appoint military representatives who sign the disposal manifests and take on the responsibility and legal liability for all HW created and disposed of within the limits of USAG Bavaria;

• The direct waste generators are most knowledgeable on the amount, contents and type of waste collected. Neither the DLA-contractor, nor the DLA COR or the HW Manager can vouch for contents of containers since they did not fill them;

• The EOs may delegate individual tasks to trained personnel. However, they need to provide oversight and be confident in their abilities. Use EO training records to document and delegate trained personnel;

• The FGS requirement for maintaining a cradle-to-grave audit trail is fulfilled by tracking hazardous waste from point of generation thru disposal.

4.1.3 Why Maintain a HW Audit Trail?

Maintaining an audit trail is not just an FGS requirement, but also has the following benefits:

• Generators are given the responsibility for ensuring that the profile sheets match the type of waste, and for controlling access to containers;

• Quantifies HW generated at the unit level and allows tracking containers back to the generator;

e.g. when waste was rejected by the HN disposal facility due to improper segregation and waste description;

• Identifies personnel requiring EO training;

• Can reduce costs by avoiding unnecessary mixing of different types of hazardous waste, such as latex paint (non-hazardous, regular refuse) with solvent-based paint (hazardous).

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Hazardous Waste Audit Trail Workflow

Figure 4-1: HW Audit Trail Workflow

Note: Fig.s relate to documents shown in Annex 3.

no yes

Is HW Profile Sheet available?

(fig. 1)

Pick up of HW is required

DLA contractor checks filling level of container and initiates removal

Generatorprepares HW profile (fig. 1) sheet for new waste streams

DLA issues task order DD Form 1155

Generator fills out “Internal HW Audit Trail “ form (fig. 2)

DLA contractor creates and Env Div HW Mgr approves DD Form 1348-1A)

Appointed military person signs "Begleitschein

Contractor picks up and properly disposes of HW

Generator forwards HW profile sheet to DLA Contract COR & and ENV Division

DLA HW contractor marks each drum

Fig. 2

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IMPORTANT NOTICE:

Failure to complete and sign the internal audit tracking sheet will result in a High Risk finding during the next EPAAS (Environmental

Performance Assessment and Assistance System) inspection.

4.2 Procedure for Training Units

Training units will complete the internal audit trail sheet when delivering hazardous waste to the former Sanitary Landfill and provide it to the landfill operator. Forms are available from Environmental Division.

Use Table A2-1 to determine your waste streams. Please write or print legibly. Complete the audit trail sheet as follows:

• Write down building/range and unit name;

• Enter the Contract Line Item Number (CLIN) and name of waste – use table under Annex 2 to determine your waste stream. Please use the waste descriptions and CLIN’s included in this table when completing the form. If unsure of the type of waste, contact the HW Manager for assistance at DSN: 476-2932 (Rose Barracks), or at DSN: 475-7209 (Tower Barracks);

• Write down container type, size and quantity, i.e. metal drum, 55 gal, 1 ea.;

• Estimate weight of container(s), leave blank if unknown;

• Print name and rank of POC / EO, phone number and sign the audit trail sheet;

• Under “comments” provide the address of your home station.

Appointed military personnel will electronically sign waste disposal manifests!

In addition, the Environmental Division will ensure that the disposal documentation provides proper waste classification according to the German KrWG and all required information is entered into the document.

Note: Unopened, unused, excess, or expired HM will not be accepted for disposal and must be reported to the Directorate of Logistics (DOL) HMRC, DSN: 475-6065 / 476-2521.

This is a CONTROLLED DOCUMENT printed for reference only. Original is kept at the Environmental Division January 2020

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5 HOUSEHOLD-TYPE HAZARDOUS WASTE AND WASTE

ELECTRONICS

Any household type hazardous waste or waste electronics (e-waste) accumulated in offices or troop billets shall NOT be disposed of as regular trash. Refer to the Household Hazardous Waste Disposal Guide under Tab I of the Tenant Unit SOP.

6 TONER RECYCLING AND DISPOSAL MANAGEMENT

6.1 Collection

• LRC BA HAZMAT (HMMP) is the focal point for all new and unused toner collection and re-issue / re-use / free-issue. Anyone with excess or unwanted new toner can turn them in to our HAZMAT RE-ISSUE CENTER, located at Rose Barracks, Bldg 121, Room 23 (Duty Phone 476-2512 or 476- 2678).

• If an activity in garrison (mil or civ) has a large number of excess/unwanted new toner cartridges, onsite pick-up by our staff is possible. This is typically handled on a case-by-case basis. Customers would simply contact our office via phone or team email address. Our goal is to be very responsive to obtain the greatest possible volume of unwanted/excessive toners from the Garrison footprint.

The sooner we can obtain them, the better the chance that there may be another customer who may have need for the item.

• LRC BA HAZMAT (HMMP) is also the focal point regarding collection of used/expended toner cartridges/ink cartridges for recycle. In partnership with USAG BA, DPW / Environmental Division, our HAZMAT personnel established a used toner management program to act as the centralized contact for used toners. Within Bavaria, unwanted/used toner cartridges, if disposed, must be managed as hazardous waste. The HAZMAT team collects, inspects, sorts and manages the recycle of all possible toners within the garrison.

6.2 How to turn-in used toner and ink cartridges

• Turn-in at HAZMAT RE-ISSUE Center (Rose Barracks): HAZMAT will accept all used cartridges directly from any customer who wishes to deliver or drop them off at the Rose Barracks HAZMAT RE-ISSUE CENTER (Bldg 121, Room 23). Simply show up and download.

• Collection boxes: HAZMAT has developed a Garrison-wide toner collection program, whereby we place specific collection boxes at various customer collection locations around the base. Customers place the used/unwanted cartridges in the collection boxes. Each two weeks either the toners from the boxes or the full boxes are collected.

• Turn-in at Vilseck office: In the event a customer collects unusually large amounts of cartridges, or the facility is locked during our scheduled collection runs, any customer can phone the Vilseck office (476-2512) and request a special pick-up; or they can also choose to deliver them to the Vilseck site.

• Collection boxes at DPW Central Recycling Center: There are two large used toner collection boxes placed at the DPW Central Recycling Center (on the tank trail). Customers can choose to deposit their cartridges at this site also. Our HAZMAT team stops at this location multiple times during the week to check and empty the large collection bins.

This is a CONTROLLED DOCUMENT printed for reference only. Original is kept at the Environmental Division January 2020

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6.3 Toner hazardous waste turn-in

Typically, the LRC BA HAZMAT program is the single source for the printer toner waste stream HAZARDOUS WASTES. Our operations maximize the recycle quantities and volumes sent back to recycler partners, or to OEMS within Europe. Some toner/ink cartridges have no present recycle outlet or markets.

It is these items that then are disposed as hazardous waste. The majority of this originates with off-brand/compatible or re-cycled/re-filled cartridges that find their way into the Garrison.

6.4 Recycle Post-paid labels

Note that even though some original toner manufactures (HP, Dell, Lexmark, etc.) routinely enclose a mailing label in their boxes of new cartridges, we don't use this US Postal mail system to return cartridges.

The Post Offices are aware we operate the Garrison recycle program and ask unit personnel not to return cartridges to vendors with the labels. Most frequently, postal personnel will refuse to ship these cartridges from CMRs. Even though the return labels 'appear' to provide free shipping, we must remember DOD pays all postal freight costs from OCONUS to the receiving CONUS-based US Post Office.

6.5 Toner management program at LRC/USAG Bavaria

The current USAG/LRC Bavaria operated toner management program establishes a holistic, life-cycle management program for printer consumables. This holistic program provides for major hazardous waste stream cost savings and reduces the volume of hazardous waste generated. It allows for collection and re-distribution of new/unwanted printer consumable assets to units that have need and generates a positive financial stream from some used cartridges to provide the Garrison with new, needed and high demand toner assets for free-issue. The initiative is beneficial for the units, the Garrison, USAREUR, the Army and especially the US taxpayers.

In case of major printer entities, such as the USAG BA/S-6 and the 7ATC/S-6, we always ask if you can be good partners with us, especially regarding printer life-cycle procurement periods. When you are procuring large quantities of replacement printers, the sooner you let us know what specific models you are receiving, perhaps we can assist you with getting the sustainable consumable items cataloged within the Federal Supply System, such that your supported personnel can order the consumables from the normal Army supply system.

Toners are HAZMAT ITEMS in the Army. And HAZMAT ITEMS are not to be procured using a GPC without specific Garrison commander approval.

For further questions, please contact Mr. Mike Donahue at DSN 476-2512, or Mr. Christian Odoerfer (DSN 475-6065 or 6789).

This is a CONTROLLED DOCUMENT printed for reference only. Original is kept at the Environmental Division January 2020

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Annex 1 - Listing of Managements Service Points / Pickup Points

Table A1-1: Management Service Points – Rose Barracks (Vilseck)

Bldg. # Unit

103 Household Hazardous Waste Collection Point

113-121 RSSA Turn in Point

124 DPW Central Hazardous Waste Collection Point

141 DPW Operation and Maintenance (O&M) Division

201 Fire Department

310 MAV HWAP

330 18 MP Company

349 Combined Arms Training Center (CATC)

359 N.N HWAP (currently used by AAFES for storage of HM)

630 Fires 2SCR Troop L HWAP

648 4/2 2SCR HWAP

657 3/2 2SCR HWAP

666 2/2 2SCR HHT HWAP

674 1/2 2SCR HWAP

711 MWR Auto Craft Shop

718 Army & Air Force Exchange Service (AAFES) (currently closed)

731 RSS 2SCR HWAP (currently closed)

732 RSS 2SCR HWAP

The contractor will schedule all removals for collection points (includes Management Services). Please inform the Environmental Division if containers are full and no removal has taken place.

Table A1-2: Pickup Points – Rose Barracks (Vilseck)

Various Dry cell batteries, Rose Barracks (approx. 50 locations)

102 DPW Recycling Center (Vehicle Batteries and Dry Cell Batteries Only)

222 Vet Clinic

250 Dental/Health Clinic

308 MAV Underground Storage Tanks (USTs)

351 Transportation Motor Pool (TMP)

549 21 TLSC/TSC, ASP#1

622 DOL Gas Station

640 4/2 2SCR Motorpool USTs

650 3/2 2SCR Motorpool USTs

652 3/2 2SCR Motorpool USTs

653 3/2 2SCR Motorpool USTs

660 2/2 2SCR Motorpool USTs

662 2/2 2SCR Motorpool USTs

663 2/2 2SCR Motorpool USTs

670 1/2 2SCR Motorpool USTs

672 1/2 2SCR Motorpool USTs

673 1/2 2SCR Motorpool USTs

685 Wash Rack

695 Motorpool

719 AAFES UST (currently not used)

721 RSS 2SCR, Motorpool USTs

726 RSS 2SCR, Motorpool USTs

5000 UAS Facility

1803 High School Vilseck

This is a CONTROLLED DOCUMENT printed for reference only. Original is kept at the Environmental Division January 2020

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Pickup Points have to request pickup at the Environmental Division when hazardous waste containers are ¾ full or seem to get full within the next two weeks. USTs are connected to the Utility Energy Monitoring and Control System (UEMCS) and fill levels are controlled by DPW.

Table A1-3: Management Service Points– Tower Barracks

710 Centralized Recycling Center

301/MP 50 BASOPS Maintenance Division

319 BASOPS Maintenance Division

2511 Grafenwoehr Army Airfield (GAAF)

TP 1/ 1030 Organizational Maintenance Activity (OMA)

TP 1/ 1060 Organizational Maintenance Activity (OMA)

Bldg. 3060 Range Warehouse

805 41st Field Artillery Brigade

825 173rd Airborne Brigade Combat Team (ABCT)

855 173rd Airborne Brigade Combat Team (ABCT)

905 18th Combat Sustainment Support Battalion (CSSB)

915 2CR Regimental Support Squadron (RES)

925 41st Field Artillery Brigade

935 15th Engineer Battalion (EN BN)

528 MWR Auto Skills Center

MP3 41st Field Artillery Brigade

394 Self Help

TP5 18th CSSB

The contractor will schedule all removals for collection points (includes Management Services). Please inform the Environmental Division if containers are full and no removal has taken place.

Table A1-4: Pickup Points – Tower Barracks

Various Dry cell batteries, Tower Barracks & Field Camps (approx. 150 locations)

Various Fire Extinguishing Residues, Airfield Fire Department

Various Contaminated Fuel/oil from Field Camps (approx. 50 pick-up points)

Various Waste Antifreeze from Field Camps (approx. 50 pick-up points)

MP 6 TBD

MP 7 TBD

MP 33 TBD

MP 51 DPW Building and Grounds (B&G)

332A LRC Reuse Center

481 TMP

305A LRC Gas Station

TP 7 DPW Carpenter

3060A Training Support Activity (TSAE) Tactical Pursuit and Containment (TAPC)

Pickup Points have to request pickup at the Environmental Division when hazardous waste containers are ¾ full or seem to get full within the next two weeks. Most USTs in Rose Barracks and some in Tower Barracks are connected to the UEMCS and fill levels are controlled by DPW. Please contact DPW when tanks are 70% full.

This is a CONTROLLED DOCUMENT printed for reference only. Original is kept at the Environmental Division January 2020

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Table A1-5: Pickup Points – Garmisch Military Community

Bldg. # Unit

Next to Bldg. 202 BASOPS Maintenance Division

Next to Bldg. 257 HW Collection Point

Table A1-6: Pickup Points – Garmisch Military Community

10 Different locations on Artillery Kaserne where containers for dry cell batteries are placed.

This is a CONTROLLED DOCUMENT printed for reference only. Original is kept at the Environmental Division January 2020

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This is a CONTROLLED DOCUMENT printed for reference only. Original is kept at the Environmental Division January 2020

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Annex 2 - Instructions for Waste Collection and Segregation

Table A2-7: HW Collection and Disposal

Name of Waste CLIN Disposal Remarks

Aerosol cans

N2420 If property is used, opened, or unserviceable, dispose of in 60 liter (l) drum at HWAP or take to one of the following locations:

Rose Barracks: Central HW Collection Point at Bldg. # 124.

Tower Barracks: Sanitary Landfill across from Range 118.

Garmisch: Place in appropriate 200 l drum.

Collect with the cap on!

No pesticides!

Antifreeze

N2570 Rose Barracks: Drain into UST for antifreeze at the motor pool, into the labeled 55 gal drum or in Aboveground Storage Tank (AST) provided by the contractor (Bldgs.

# 630, 640, 353 will use contractor provided containers, all others have underground storage tanks).

Tower Barracks: Either use UST or the container provided by the contractor.

Garmisch: Use container provided by contractor.

Battery acid

N1300 Rose Barracks: Drain into UST for battery acid (Bldg. # 308).

Tower Barracks: Contact the Environmental Division for assistance.

Garmisch: Contact DPW (Mr. Klumpp) for assistance.

Batteries, dry cell

N0440 Place in 60 l plastic drum or red container and request removal from Environmental Division when ¾ full.

Batteries, lithium

N0400 Rose Barracks: Place in 60 l plastic drum, take to DPW Central HW Collection Point at Bldg. # 124 or request removal through the Environmental Division.

Tower Barracks: Place in 60 l blue drum for disposal or take to the Sanitary Landfill.

Garmisch: Request assistance from DPW (Mr. Klumpp).

Ensure lithium batteries are completely discharged before disposal, as they can release hazardous vapors. Connectors must be taped or complete battery is placed in plastic bag.

Never mix lithium batteries with other batteries.

Batteries, magnesium

N0410 Rose Barracks: Place in 60 l plastic drum, take to DPW Central HW Collection Point at Bldg. # 124, or request removal through the Environmental Division.

Tower Barracks: Place in 60 l blue drum for disposal or take to Sanitary Landfill.

Garmisch: Request assistance from DPW (Mr. Klumpp).

Batteries, nickel-cadmium

N0420 Place in 60 l plastic drum and request removal through Environmental Division when ¾ full.

This is a CONTROLLED DOCUMENT printed for reference only. Original is kept at the Environmental Division January 2020

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Table A2-1: HW Collection and Disposal (continued)

Batteries, vehicle

N0470 Rose Barracks: Place into container provided by contractor at: Recycling Center, Bldg. # 107; Auto Craft Shop Bldg. # 711; CST, Bldg. # 147; AAFES Garage, Bldg. # 718; or turn in at RSSA, Bldg. # 121 (batteries for military vehicles).

Tower Barracks: Place in container provided by contractor or take to Sanitary Landfill.

Garmisch: Turn-in to manufacturer for recycling.

Brake and hydraulic fluid

N2250 Rose Barracks: If container has been opened, take to Central HW Collection Point at Bldg. # 124 for disposal.

Tower Barracks: Use container provided by contractor or take to Sanitary Landfill.

Garmisch: Place in appropriate 30 l drum.

Cartridges, diesel starter

N0610 Rose Barracks: Place in 120 l plastic drum at HWAP, take to DPW Central HW Collection Point at Bldg. # 124 or request removal through the Environmental Division.

Tower Barracks: Place in 120 l plastic drum for disposal or take to Sanitary Landfill.

CDE kits**) N2650 Follow instructions given below. **

Requires DEMIL prior to turn-in for disposal!

Compact Fluorescent Light (CFL) bulbs

N2540 Carefully place onto pallets or into containers provided by contractor to avoid breaking and releasing noxious vapors into the air. Self Help and the Sanitary Landfill are authorized collection point.

DS2**)

N1420 Follow instructions given below. ** Requires DEMIL prior to

Fuel, contaminated

N2170 Drain into labeled 250 l or 450 l AST at the HWAP next to each motor pool.

GTA: Contact the Environmental Division at Grafenwoehr for disposal options.

More than 500 gal: If fuel has not been tested prior to requesting disposition, the unit shall submit a sample of the fuel to DLA Energy Petroleum Laboratory in Kaiserslautern, Germany, using DD Form 2927 (petroleum and lubricant sample identification tag). Contact the laboratory at DSN: 314-493-2668/2685.

Address:

DLA Energy Petroleum Laboratory

CMR 422

APO AE 09067

This is a CONTROLLED DOCUMENT printed for reference only. Original is kept at the Environmental Division January 2020

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Glues and adhesives

N1950 Rose Barracks: If container has been opened, take to DPW Central HW Collection Point at Bldg. # 124 for disposal.

Tower Barracks: Contact the Environmental Division.

Grease, waste N2180 Rose Barracks: If container has been opened, take to DPW Central HW Collection Point at Bldg. # 124 for disposal.

Tower Barracks: Take to Sanitary Landfill.

Mask filters **) N1830 Follow instructions given below. ** Requires DEMIL prior to

Metal cans, previous hazardous residues > 5 gal, 55 gal, empty, drained

N2610 Turn in at the Sanitary Landfill.

Metal cans, previous hazardous residues < 5 gal

N2600 Place into ASP container (container for solid HW), or 10 cubic meter (cbm) container labeled "EMPTY METAL CANS" at your motor pool. Cans must be completely empty. Soda cans will not be accepted, they go into the blue recycling container.

POL contaminated solids (oil contaminated absorbent, oily rags, non-ferrous POL contaminated wastes)

N2190 Includes empty plastic cans with hazardous residues (up to 5 gal size), oil-contaminated absorbent and oily rags. Place into ASP container or 10-cbm container labeled "OIL CONTAMINATED SOLIDS" at your motor pool. Plastic oil cans must be completely empty. Do not use the container only for contaminated absorbent, since it will be too heavy to be emptied.

Used Oil Filters N2210 Place into 200 l drum labeled "OIL FILTERS" at your motor pool HWAP. Only oil and fuel filters will be accepted. No air filters!

No air filters!

Paint, halogenated N1900 Rose Barracks: If container has been opened, take to DPW Central HW Collection Point at Bldg. # 124 for disposal.

Tower Barracks: Take to Sanitary Landfill.

Garmisch: Request assistance from DPW (Mr. Klumpp).

Chemical Agent Reactive Coating (CARC) paint must be packed separately.

LATEX Paint will not be accepted. Must be disposed of as regular refuse.

Paint, non-halogenated N1910 Rose Barracks: If property is used, place into 120 l drum at your motor pool HWAP.

Tower Barracks: Take to Sanitary Landfill.

Garmisch: Request assistance from DPW (Mr. Klumpp).

CARC paint must be packed separately.

No latex paint!

Plastic cans – empty (previous hazardous residues): > 5 gal

N2630 Turn in at Sanitary Landfill

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Solvents, non-halogenated

N 1610 Rose Barracks: If container has been opened, take to DPW Central HW Collection Point at Bldg. # 124.

Tower Barracks: Take to Sanitary Landfill.

Garmisch: Request assistance from DPW (Mr. Klumpp).

Halogenated and non-halogenated paints must be kept separate!

Solvents, halogenated

N 1630 Rose Barracks: If container has been opened, take to DPW Central HW Collection Point at Bldg. # 124.

Tower Barracks: take to Sanitary Landfill.

Garmisch: Request assistance…