C12_Att_06_Kpt_EV_Guide_for_Contractors_Jan_2025.pdf

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GUIDE TO

ENVIRONMENTAL COMPLIANCE

REQUIREMENTS

FOR

CONTRACTORS AND

SUBCONTRACTORS

Online document is the master. Printed copy is an uncontrolled copy Document Control Point: Environmental Code 1023

NUWC Division, Keyport Environmental Contractor Guide January 2025

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Environmental Compliance Requirements for Contractors and Subcontractors Revision Status

REVISION ISSUE

DATE

BRIEF DESCRIPTION OF CHANGE

NR 30 JAN 18 Initial Release

1 16 OCT 19 Revised, updated, and clarified guidance. Revised manual to make it consistent with Naval Base Kitsap (NBK) guidance and practices.

2 4 DEC 20 Some minor format changes.

3 Nov 2024 Streamlined format for consistency; updated program requirements.

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ABOUT THIS GUIDE

Compliance with all applicable federal, state, local laws, and Department of Navy (DoN) environmental requirements is mandatory. This Contractor’s Guide is provided to help assist contractors with complying with environmental requirements while working on base.

This guide is intended to provide general guidance for contractors working within the Naval Base Kitsap (NBK) Keyport installation of which Naval Undersea Warfare Center (NUWC) Division, Keyport is the primary tenant. Where the guide references the “Base Environmental Office (BEO)” the document is referring to the point-of-contact listed in the guide’s BEO telephone listing. These points of contact may be Naval Facilities (NBK) or NUWC Division, Keyport personnel depending upon internal DoN roles and responsibilities and host-tenant command support agreements. All contractor BEO coordination should be coordinated through the contracting officer’s representative and/or contracting officer.

This document is for guidance and training purposes only. It remains the contractor’s duty to comply with all applicable laws, regulations, and local requirements and this guide alone cannot assure such compliance. To the extent the guidance contained in this document conflicts with contract specifications, the contract specifications are the controlling document. If the contractor believes this guidance conflicts with contract specifications, these concerns shall be addressed with the contracting officer and/or Contracting Officer’s Representative (COR).

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EMERGENCY RESPONSE INFORMATION WHILE WORKING

ON BASE

When an emergency happens (medical assistance, fire, flooding, spill response, etc.)

minutes matter and valuable time can be lost if searching for an emergency contact or location information.

IMPORTANT: There are different numbers to call at NUWC Division, Keyport depending upon what phone system you are calling from.

When using a personal or company supplied mobile phone or a non-DoN phone call:

When using a DoN phone on a DoN exchange call:

DoN Regional Dispatch Center:

Emergency Phone: 360-396-4444

Non-Emergency Phone: 360-315-4064

NOTE: All 911 calls made on DoN property from mobile phones or non-DoN phones are routed to Kitsap County Central Command, which must then relay your information to the DoN Regional Dispatch Center. This is an unnecessary additional step, which could delay response.

DoN Regional Dispatch Center:

Emergency Phone: 911 Non-Emergency Phone:

360-315-4064

NUWC Division, Keyport Duty Office Only:

Non-Emergency: 360-396-2244

Critical information the dispatcher needs to know:

WHAT BASE ARE YOU CALLING FROM? NUWC Division, Keyport WHERE IS THE EMERGENCY? Give the address, nearest cross street, and include building number, spelling out, (e.g.; Building one-zero-five-zero, instead of building ten-fifty.)

WHAT'S THE EMERGENCY? Medical, hazardous material spill, explosive incident, fire (smell of smoke, etc.)

WHO NEEDS HELP? Age, gender, and number of people.

Once you have relayed the information, the dispatcher will verify it so don’t hang up yet!

Remain calm and give direct answers to the questions asked. Speak slowly and clearly.

The dispatcher will ask additional questions so they can send the right type of help. All questions are important. The dispatcher may also provide you with CRITICAL PRE- ARRIVAL INSTRUCTIONS, so listen carefully. Lastly, ensure someone with knowledge of the emergency is standing by at the building entrance or street corner to flag down responding units and escort them to the scene.

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Below are designated points of contact for various environmental program areas. These individuals may provide information and guidance but are not authorized to provide direction to contractors. Only the contracting officer is authorized to make final determinations on appropriate actions. For general environmental compliance information related to projects, the environmental project coordinator will be the primary environmental office point of contact and should be able to direct any questions to the appropriate program manager or subject matter expert.

Environmental Project Coordinator (NUWC Division, Keyport)

(360) 396-5430

Environmental Project Coordinator (NBK Bangor) (360) 994-8672

Environmental Director (NBK Bangor) (360) 314-5411

Environmental Director (NUWC Division, Keyport) (360) 315-0946

Environmental Office POCS

Air Discharges and Ozone Depleting Substances (360) 396-5878

Asbestos Management (NBK Bangor) (360) 315-3833

Hazardous Material Management (360) 396-5438

Hazardous (Dangerous) Waste Management (360) 396-2320

Installation Restoration (Contaminated Superfund Sites (360) 564-9474

Solid Waste Management (NBK Bangor) (360) 396-7005

Spill Prevention and Response Planning (360) 315-8571

Spill Prevention and Response (SPCC) and Tanks (UST’s &

AST’s)

(360) 315-8571

Storm water (360) 315-1992

Water Quality, Sewer/Wastewater Discharge (360) 315-8571

Forestry (360) 396-0079

Environmental Services

Hazardous Waste Services (labels, drums, pickups, etc. (360) 396-7992

Email:

kypt_wa_tsdf@us.navy.mil

Hazardous Waste Designation (360) 396-7991

BASE ENVIRONMENTAL TELEPHONE LISTING

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TABLE OF CONTENTS

ABOUT THIS GUIDE

EMERGENCY RESPONSE INFORMATION WHILE WORKING ON BASE

BASE ENVIRONMENTAL OFFICE TELEPHONE LISTING

INTRODUCTION

ENVIRONMENTAL COMPLIANCE

ENVIRONMENTAL TRAINING

SPILL PREVENTION AND RESPONSE 11

Storage Tanks and Oil Filled Equipment Preventative Measures Required Training for Petroleum Transfers Spill Events Non-Emergency Spill Event Emergency Spill Event 13

HAZARDOUS MATERIAL MANAGEMENT

Hazardous Material Management and Approval Restricted Hazardous Materials

WASTE MANAGEMENT

HAZARDOUS (DANGEROUS) MATERIAL MANAGEMENT 15

Waste Determination (Designation) Waste Sampling Waste Containers Waste Labeling Waste Accumulation Areas Waste Pickup, Shipment, and Disposal Solid (Non-Hazardous) Waste Management 19

RECYCLING

POLYCHLORINATED BIPHENYLS (PCBs)

CLEAN WATER 22

Drinking Water 22 Stormwater 22 Stormwater Pollution Prevention Plan 23 Pressure Washing 25 Wastewater and Sanitary Sewer Discharges 25

CLEAN AIR 27

Refrigerants and Ozone Depleting Substances (ODS) 27 Air Contaminant Generating Processes and Equipment 27 Temporary Portable Non road Engines for Projects 28 Common Clean Air Act Concerns for Projects 29 Asbestos 29

DEMOLITION

Site Approvals and Environmental Considerations during Demolition Projects Clean Air and Asbestos Considerations for Demolition Projects

CONTAMINATED SITES

EXCAVATION

NATURAL RESOURCES

FORESTRY

CULTURAL RESOURCES 35

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APPENDIX A- EXAMPLE FORMS 36

Note- Forms listed in Appendix A are Examples provided for training and background and are not maintained up to date. Current up-to-date versions of Submittal forms should be obtained from the Project Manager and/or BEO.

1. CHMI 37

2. WGR 38

3. Site Registration Form 39

4. Waste Disposal Request Form 40

5. Waste Pickup Form 41

6. Hazardous Waste Site Inspection Form 42

APPENDIX B 43

APPENDIX C 45

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INTRODUCTION

The DoN is committed to being a good environmental steward; operating in a manner compatible with the environment and in compliance with environmental regulations.

NUWC Division, Keyport’s Environmental Policy proclaims the DoN will operate in an environmentally responsible manner while performing its mission, and any company under contract with the DoN, must also provide a personal commitment to environmental protection.

ENVIRONMENTAL POLICY

It is the Environmental Policy of NUWC Division, Keyport that we are committed to:

Conducting business in an environmentally responsible manner that promotes pollution prevention, resource conservation, and environmental stewardship.

Operating our processes in compliance with applicable legal requirements and with other requirements that relate to our environmental aspects.

Continually improving our workplace to reduce environmental risk.

Developing annual targets to serve as guidance for planning and operations.

Ensuring this policy is communicated to all persons working for or on our behalf and is available to the public.

This commitment is important regardless of whether your job is large or small. Whether you are involved in a major construction project or a small paint job, it is mandatory to consider the environment in all of your operations. Your awareness and participation are vital to the success of the DoN’s mission and our ability to comply with the various environmental laws.

To support the DoN’s environmental policy, all contractors working at NUWC Division, Keyport should be knowledgeable of:

NUWC Division, Keyport’s environmental policy (included above), Potential environmental impacts/aspects associated with their work, and

Emergency response procedures while working on base.

Environmental regulations continue to evolve and change. NUWC Division, Keyport operates under separate discharge permits for air emissions, wastewater/sewer discharges, and storm water discharges. Specific to hazardous waste (HW), NUWC Division, Keyport operates as a large quantity generator. Compliance with environmental regulations requires specialized knowledge and expertise. The BEO will provide information that will help in understanding environmental compliance responsibilities while working on base.

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ENVIRONMENTAL COMPLIANCE

“Environmental compliance” means conforming to all applicable environmental laws/regulations including site-specific permits and program requirements. The cost of environmental compliance is a legal responsibility. Non-compliance is far more costly over time as consequences of serious violations can include individual penalties and civil/criminal charges, as well as bad publicity, which will affect relations with the community and the ability to receive new contracts. Contractors must always include environmental compliance in their policies, procedures, and operations.

Large projects such as construction projects will have environmental controls specified in the contract. The contract will specify if a formal Environmental Protection Plan must be submitted to the contracting officer for review and comment (a generic Environmental Protection Plan template is available upon request). If this requirement is not specified in the contract, a meeting with members of the BEO is recommended and may be required by the contract prior to starting the job to ensure that the contractor has an adequate understanding of all applicable requirements and site specific considerations for working at NUWC Division, Keyport.

All contractors and contractor personnel are required to comply with all applicable federal, state, and local environmental laws and regulations applicable to the work they are performing at all times. It is incumbent upon the contractor to know, understand, and follow all relevant rules and regulations pertaining to protection of the environment while performing work for which they are contracted.

Additionally, there may be project and site specific considerations to ensure compliance with environmental rules and regulations while performing work in conjunction with the government at NUWC Division, Keyport.

Potentially significant environmental considerations for working at NUWC Division, Keyport depending upon the specific work to be performed includes, but is not limited to:

Knowing the emergency response numbers and procedures at NUWC Division, Keyport.

Hazardous material (HM) approval and management procedures for use of HM at NUWC Division, Keyport.

How to properly manage and dispose of solid waste, recyclable waste, and HW on base.

Your requirements, roles, and responsibilities for specific environmental impacts known to be applicable to the work being performed.

Understanding your responsibilities related to existing government permits applicable to the work being performed.

If it is not clear how these considerations should be addressed during your project, you should request clarification from your COR.

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ENVIRONMENTAL TRAINING

In addition to compliance with all applicable federal, state, and local environmental laws and regulations, all contractors and contractor personnel are required to comply with applicable certification and training requirements related to the work performed.

Depending upon the work being performed, DoN instructions and existing facility permits may require that contract employees receive additional site-specific environmental compliance training prior to beginning work onsite. This Contractor’s Guide is provided to help assist contractors with complying with environmental requirements while working on base.

NUWC Division, Keyport has developed general environmental awareness training for personnel working onsite, which is designed to meet all site-specific awareness level environmental training requirements for working on-base. Awareness training specifically satisfies personnel awareness level training requirements for emergency response, NUWC Division, Keyport’s Environmental Management System, storm water pollution prevention, hazardous waste (HW) management, and base environmental protection programs.

For work being done at NBK Bangor, NBK Environmental utilizes ECATTS for general awareness training and also provides monthly in person training.

Additionally, groups that generate and manage HW at NUWC Division, Keyport are required to appoint a HW site manager and HW site manager alternate. HW site managers and alternates receive more detailed training on HW management procedures and requirements while working on base than general awareness level training.

Site specific government provided training does not relieve the contractor from knowing and complying with all federal, state, and local training and certification requirements necessary in order to perform the duties specified in the contract.

Site specific government provided environmental training is available from the BEO in person and electronically and should be scheduled through the project COR.

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Spill Prevention and Response Spill Program Manager NUWC Division, Keyport Code 1023, 360-315-8571

Program Summary

To ensure protection of Washington waters, land, air, and natural resources from the impacts of oil and hazardous substance (OHS) spills, you must operate in a manner that will provide the best protection for the environment. Implementing the following procedures will help reduce the risk of a spill occurring and minimize the potential impacts if a spill does occur.

Storage Tanks and Oil Filled Equipment

NUWC Division, Keyport has many above ground storage tanks (ASTs), transformers, generators, and oil filled operational equipment. Due to the quantity of oil in storage at NUWC Division, Keyport, an oil spill prevention control and countermeasure (SPCC) plan is required to meet the Environmental Protection Agency (EPA) regulations of 40 CFR 112. The purpose of the SPCC plan is to describe the general operating design/procedures that affect the facility’s potential for the discharge of oil products (which includes oil in any form) and to document measures taken to prevent discharges of oil into waters of the United States. It also describes procedural, structural and equipment improvements, and/or upgrades that must be implemented to satisfy the requirements of 40 CFR 112 for over water transfer of oil.

Oil in any form in containers of 55 gallons or larger is subject to the regulations of 40 CFR 112 (known as the “SPCC Rule”). Any new oil containers of 55 gallons or larger brought on base must be listed in the NUWC Division, Keyport SPCC plan and follow the SPCC rule. Any repair, change in location, or alteration to any underground storage tank (UST), AST, oil container, or oil filled operational equipment must be reported to the BEO so it can be documented in the SPCC plan and to ensure that there are adequate spill containment controls in place. Any new USTs or changes to existing USTs or their ancillary systems must also be in accordance with federal, state, and local requirements and reported to the BEO.

Additional information regarding OHS storage and OHS storage tanks, may be obtained from the BEO via the

COR.

Preventative Measures

All OHS handling and transfer equipment shall be inspected prior to use and during operation to ensure equipment is in proper working condition. All connections and transfer points shall be carefully checked prior to, during, and after transfer operations to monitor for leaks. Hose connections shall be wrapped and/or containment placed under them. All storm drains near the transfer location shall be covered with temporary storm drain mats.

All OHS shall be carefully controlled and all OHS liquid storage areas must be properly managed. Areas that can impact the storm water system must have discharge control structures (e.g., curb, sumps, secondary containments, or other types of spill prevention) to contain potential spills, leaks, and discharges. Storage of OHS containers in uncovered secondary containment locations must have provisions for sampling of, controlled draining of, and proper disposal of storm water that accumulates in the containment area. You, as a contractor, are responsible for storing your OHS only in authorized areas and in an authorized manner.

NUWC Division, Keyport will respond to all spills, but contractors must provide a spill response kit and discharge control devices for any handling and transferring operation involving OHS. The kit needs to contain items appropriate for the clean-up of the type of spill that could occur. If you have any questions concerning this requirement, please contact the base environmental office.

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Training Requirements

The Washington Department of Ecology requires that all personnel involved in bulk petroleum handling operations are certified. Certification is accomplished by successful completion of a training course in Oil Spill Prevention and response. Key supervisory and operations personnel must have a certification that meets the requirements of WAC 173-180C.

Key operations personnel are identified as employees with direct involvement in the transfer, storage, handling, or monitoring of oil (e.g., person-in-charge, storage tank operators, or oil transfer monitors).

Key supervisory personnel must directly supervise the transfer, storage, handling, or monitoring. Before conducting any OHS transfer at NUWC Division, Keyport, you are responsible for ensuring your personnel are trained to the state and facility specific requirements before starting the operation. Over-water OHS transfers are subject to additional requirements and must be coordinated with the BEO.

Additional help or clarification on the required training for certification may be obtained from the BEO via the COR.

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Spill Events Spill Coordinator NUWC Division, Keyport Code 1023, 360-315-8571

Program Summary

A spill event involves the unauthorized spilling, leaking, pumping, emitting, emptying, discharging, injecting, escaping, leaching, disposing, or dumping of oil or a hazardous substance. Spill events are categorized as non-emergency or emergency. All spill events, regardless of whether they are classified as an emergency or non-emergency spill event, must be reported by dialing 360-396-4444.

Non-Emergency Spill Event

A non-emergency spill event is a discharge of a known material or any hazardous substance that can be cleaned up as part of normal housekeeping by the personnel who discovered the spill. The spill does not pose an immediate threat to human health or the environment and is not released on the soil, into any waterway inlet (e.g., storm drain), or outside NUWC Division, Keyport’s boundaries.

Actions Required:

Stop the source of the spill.

Call 360-396-4444 and report the event.

Contain the spilled material by keeping the spill away from drains or waterways and by blocking off drains located near the spill if the spill may reach them.

Clean up the spilled material wearing the proper personal protective equipment.

Dispose of the spill debris properly (see Waste Management sections of the guide).

Emergency Spill Event

An emergency spill event is any release of a known or unknown material or hazardous substance that poses an immediate threat to human health or the environment. In these situations, the individual that discovers the spilled material must immediately dial 360-396-4444 to report the incident. All unpermitted or uncontrolled releases on land, or discharged to any waterways or outside base properties, are classified as emergency spill events.

Actions Required:

Immediately take action as appropriate to contain or stop the source of the spill if this action can be taken without jeopardizing the health or safety of yourself or other people.

If the properties of the material are unknown or they are a threat to human health, evacuate the area and go upwind.

Immediately dial 360-396-4444 and provide the requested information.

Warn others in the area and direct them upwind.

Make yourself available to emergency response personnel.

Provide Safety Data Sheets (SDS) for the spilled material to the emergency response personnel.

Notify the Contracting Officer.

Training Requirements: No specific training requirements; please contact BEO for additional questions regarding the above information.

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Hazardous Material Management HM Program Manager, NUWC Division, Keyport Code 1023, 360-396-5438

Program Summary

“Hazardous Material (HM)” is defined as any material that, because of its quantity, concentration, or physical, chemical, or infectious characteristics, may pose a substantial hazard to human health or the environment.

Hazardous Materials Requirements

All HM’s to be brought within the fence line of NUWC Division, Keyport must:

Be accounted for on a contractor hazardous material inventory (CHMI) worksheet (see Appendix A);

Be reviewed and approved by the BEO;

Have a SDS provided to the BEO and at the location where the HM is being stored;

Be labeled with the following:

o “Contractor Owned Material” o Company Name o Primary POC for HM management w/ phone number

If additional HM’s are needed or significant quantity changes are made as work progresses, a new CHMI must be submitted and approved through the BEO prior to bringing the HM on station.

Contractors are responsible for ensuring that while on base, their HM is stored safely and in compliance with applicable federal, state, and local regulations so that the material does not become a safety, fire, or spill risk.

All unused or partially used HM that is brought on base by the contractor for the performance of their work is the property of the contractor and must not be left at the facility or turned in to the government for disposal as HW unless outlined in the contract.

Note: Some products contain chemicals that pose a significant risk to human health or the environment and their use may be prohibited at NUWC Division, Keyport. The contracting officer may consider exceptions to the use of any of the prohibited materials upon written request by the contractor, and with BEO approval via the COR.

Training Requirements: No specific training requirements; please contact BEO for additional questions regarding the above information.

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Waste Management Waste Program Manager, NUWC Division, Keyport Code 1023, 360-396-2320

Program Summary

The composition and estimated quantity of each waste expected to be produced as part of your project should be identified. For larger projects, this information is typically included within the project specifications.

Each waste that will be produced must be categorized as HW, refuse, or recyclable material. A waste is considered hazardous if it meets certain levels of reactivity, ignitability, corrosively, or toxicity, or is otherwise listed as a HW. The State of Washington regulates more waste as hazardous than mandated by federal law and has adopted the term “dangerous waste” to include federal HW and state regulated waste.

Proper waste management coordination is not only needed for compliance, it also benefits projects by preventing time delays or operational shutdowns and improves public relations. Therefore, it is always beneficial to maintain a proactive approach to ensure that waste is handled and properly disposed of in a timely manner.

Hazardous (Dangerous) Waste Management Requirements

The NUWC Division, Keyport facility is regulated as a large quantity generator of HW. All HW generated onsite must be designated at the point of generation and managed in accordance with NUWC Division, Keyport’s dangerous waste management plan and procedures and WAC 173-303 requirements for large quantity generators.

NUWC Division, Keyport uses the terms HW and dangerous waste interchangeably, so use of the term HW in this guide includes all waste regulated by Washington State.

HW management and compliance with HW management requirements is a responsibility, which must be planned for and accepted as a cost of doing business with the government.

Waste Designation and Profiling

Waste designation is the process of determining whether a waste meets the requirements of a hazardous (dangerous) waste. All waste, not just the waste that is known to be dangerous or hazardous, is required to be designated at the point of generation, to ensure proper storage and management of the waste. HW is required to be managed properly and accounted for from the point where the waste is generated (cradle) to the point where it is finally disposed of and determined to no longer be hazardous (grave).

As the owner of the facility, and owner of the facility’s EPA Waste ID#, the DoN is responsible for determining whether waste generated at the facility meets the requirements of hazardous (dangerous) waste.

Designation of waste at NUWC Division, Keyport is performed by the contractor and is documented using the Waste Generation Record (WGR) /form (an example of a WGR form is included in Appendix A). The project HW site manager/alternate submits a WGR form to the BEO for each waste stream that will be generated while working on-base as part of the contract. Waste profiling will be performed by the BEO.

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In some cases, it may not be known whether a waste is a HW until testing can be conducted to verify the waste’s dangerous characteristics. In such cases, the waste containers shall be put into separate secondary containment, based on the type of waste contained, and labeled as “Waste Awaiting Profiling (WAP)” along with the most probable waste hazards, if known (for example flammable liquid/solid, corrosive, toxic, etc.). WAP containers, shall be managed as HW and labeled with known or reasonably expected hazards, until determined otherwise, but should be physically segregated from containers of known designated HW.

The project HW site manager/alternate will be expected to fill out the WGR form to the best of their knowledge and provide any information requested in order for the government to properly and accurately profile the waste.

Waste Sampling

At times, it is necessary to sample and analyze waste to determine whether the waste meets the definition of HW. The BEO will determine the required analysis necessary in order to properly and accurately designate waste. The contract will specify whether sampling and analysis services for HW designation is the responsibility of the contractor or the government.

Typically, sampling and laboratory analysis for waste designation for projects is conducted by the BEO. If waste designation sampling and analysis will be conducted by the BEO, you will need to coordinate with the COR to partner with BEO personnel to obtain a representative sample(s) of project waste streams.

If the contractor is to provide sampling and analysis services for waste profiling as part of the contract, contract sampling personnel must be trained and proficient in required environmental sampling techniques and procedures and contract laboratories must meet applicable accreditation standards for the analysis being conducted.

If you will be providing sampling and analysis services as part of the project, sampling personnel qualifications and laboratory, accreditation should be included within the project’s contract submittals.

Waste Containers and Labeling

Container Management HW generated during work on base must be stored in appropriate containers immediately at the point where the waste is produced. Projects must have proper containers on-hand to contain HW, BEFORE any HW is produced.

General tips and guidelines for container management:

Maintain containers closed at all times, except when waste is being added or removed. Containers with liquids must be closed and secured with ring and bolt, or bung screwed in (wrench tight) and provided with secondary containment that will contain 100% of the single largest container present and at least 25% of all containers. Containers with solids must have snug fitting lids. Containers containing volatile organic compounds, must meet appropriate requirements for adequately containing vapors.

No items except waste specifically designated for the container may be placed in the container.

Only re-use containers for the same waste stream.

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All containers must be appropriately labeled (see labeling) and positioned so that the labels are clearly visible. Place the labels on the side of the upper one-third of the drum whenever possible. When using roll-off boxes, place labels on the door of the container.

Maintain a minimum of 30 inches of aisle space between each row of containers, so that all containers can be readily inspected, and material handling and emergency response personnel can access all containers.

The contract will specify who is responsible for supplying containers for storing HW while working on base. If the contract does not specify or is unclear, immediately notify the COR.

If it is your responsibility to provide HW containers, ensure the containers used meet all federal, state, and local requirements for storage and transportation of the waste that will be stored in it. It is also recommended that consideration be given to optimizing the size of the containers for ease of handling, transport, and management.

If it is the government’s responsibility to provide HW containers for the project, containers will be supplied by the BEO. Contact the BEO through the COR to schedule container pickup/delivery.

HW Services (Labels, Drums, Pickups, etc.) (360) 396-7992 HW Services Email:

kypt_wa_tsdf@us.navy.mil

Container Labeling

All containers containing HW must be labeled appropriately in accordance with federal, state, and local environmental regulations. Labels must include the words “Hazardous Waste” and be at least ½ in size to be visible from 25 feet away.

The BEO will supply the appropriate waste labels (i.e., HW,WAP, and DOT) for waste produced by projects at NUWC Division, Keyport. Empty containers shall be labeled clearly as “Empty.” Contact the BEO to schedule label pickup/delivery.

HW Services (Labels, Drums, Pickups, etc.) (360) 396-7992 HW Services Email:

kypt_wa_tsdf@us.navy.mil

Waste Accumulation Areas

Project HW is required to be controlled properly at the point of generation. All project HW must be stored at the project site in accordance with the waste accumulation requirements for large quantity generators. Contractor waste accumulation areas must meet Satellite Accumulation Area (SAA) and Central Accumulation Area (CAA) requirements (formerly referred to as less than 90 day accumulation areas), contained in WAC 173-303, as applicable. NUWC Division, Keyport is required to maintain an up to date record of all HW accumulation areas located on base, along with information regarding the types and quantities of HW stored in those areas to ensure effective emergency management planning.

General tips and guidelines for establishing and managing Waste Accumulation Areas:

Locate project SAA’s and CAA areas in order to minimize the potential impact of spills. Pick a site that minimizes weather impact. If possible, avoid siting accumulation areas over the water or upslope from the water or a storm drain. Consider the use of curbing or storm drain protectors to minimize the impact of potential spills.

Ensure fire extinguishers are available and emergency response signage is adequately posted.

NUWC Division, Keyport Environmental Contractor Guide January 2025 mailto:kypt_wa_tsdf@us.navy.mil

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Accumulation start dates must be accurately maintained. Waste from SAA’s must be transported to a CAA day site or to the building 1051 Treatment, Storage, and Disposal (TSD) within 72 hours of filling the waste container. Waste from CAA sites must be transported offsite or to the building 1051 TSD within 90 days of the waste being generated.

Ensure accumulation areas are used only for the storage of HW and waste awaiting designation. Do not store HM, materials, or other equipment within project waste accumulation areas.

All project accumulation areas must have appropriate signage. Signs reading “HAZARDOUS WASTE ACCUMULATION AREA” and “DANGER - UNAUTHORIZED PERSONNEL KEEP OUT” must be posted at the entrance to the accumulation area and legible from a minimum distance of 25 feet.

“NO SMOKING OR OPEN FLAME” signs should be posted on all visible sides of the accumulation area and be legible from 50 feet.

The HW site manager and/or alternate must perform weekly documented self- inspections of accumulation areas using the HW site weekly inspection log. Name/date/time must be noted on each inspection form. The form can be found in Appendix A Item 6.

The BEO will conduct periodic inspections of facility accumulation areas and the HW site manager/alternate and the COR will be notified if any deficiencies are identified. During the duration of the project, the HW site manager/alternate should maintain a weekly logbook of their self-inspections and document any findings and corrective actions implemented. The COR and BEO should be notified of any significant findings of non-compliance.

When the project is complete, prior to closure of any accumulation area(s), any and all containers, liners, signage, or material must be removed from the site and the site returned to its original condition.

The BEO will inspect project HW accumulation areas prior to establishment and disestablishment.

Arrange for establishment and disestablishment of project SAA’s and Central Accumulation Areas by contacting the BEO and using the Site Registration Form (an example of the Site Registration Form is included in Appendix A).

HW Services (Labels, Drums, Pickups,etc.): 360-396-7992 HW Services Email:

kypt_wa_tsdf@us.navy.mil

Waste Pickup, Shipment, and Disposal

HW generated at NUWC Division, Keyport is required to be managed under NUWC Division, Keyport’s HW management program, and shipped and disposed of under NUWC Division, Keyport’s site EPA ID#.

NUWC Division, Keyport owns and operates a permitted TSD Facility on base, where HW may be safely stored, consolidated, and sometimes treated onsite. The permit for NUWC Division, Keyport’s TSD facility allows for safe storage of HW at the site for a period of time of up to one year.

Arrange for waste pickup and/or shipment for disposal with the BEO prior to project waste meeting accumulation area storage time limits. The majority of project non-bulk waste will be arranged for pickup by the BEO and consolidated and stored at the onsite TSD facility prior to eventual shipment offsite for disposal. In some instances, it may be advantageous to ship waste directly to an offsite receiving facility from the project site. In either instance, the government will determine waste shipment requirements and must maintain documentation related to the HW being shipped, the HW receiving facility, and the means by which the waste was ultimately disposed of by the receiving facilities.

NUWC Division, Keyport Environmental Contractor Guide

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The contract will specify whether HW disposal costs are the responsibility of the government or the contractor. Regardless of who is responsible for waste disposal costs, no HW may be shipped offsite by a contractor. All HW must be turned into the NUWC Division, Keyport HW TSD.

The BEO will determine appropriate waste pickup/shipment/disposal requirements for all HW. Waste pickup and disposal requirements at NUWC Division, Keyport are documented on the Waste Disposal Request (WDR) form (an example WDR form is included in Appendix A). Contact the COR to schedule waste pickup/shipment/disposal through the BEO.

Solid (Non-Hazardous) Waste Management

The term “solid waste” is used to describe designated waste that is not “HW”, “PCB”, “Universal Waste”, or “Asbestos”. This term can include construction debris, liquids, and landfill-controlled waste.

Remember that all waste must be designated prior to removal from NUWC Division, Keyport.

Solid waste shall be reported to the COR as required by contract submittals. The waste material must be identified along with whether it was reused, recycled, or disposed of, its solid waste tracking sheet (SWTS) serial number, its load numbers, and its weight. In addition, include government provided waste determination documentation that the waste was not HW (WDR).

Control and Management Place solid waste in approved and labeled containers so that it is not stored on the ground.

If recycling is an option for a waste stream, (e.g., asphalt, concrete, cardboard, scrap metals, and unpainted, untreated wood) keep it free from other types of waste.

Keep solid waste accumulation area along with the surrounding area clean and free of debris.

Liquids are not allowed in the dumpster or at the landfill. Containerize and recycle or dispose of them in accordance with applicable requirements.

Disposition

Be sure to empty containers no less than once per week unless the COR has approved a different schedule.

Vehicles and haulers used for the transportation of solid waste shall be permitted, licensed, or otherwise approved by the applicable County Health District(s).

Ensure waste is not taken to any site that has not been approved by the COR prior to removal from the work site and contractors must be sure their drivers take the waste to a location the contractors specified to the government.

Contractors are responsible to ensure no disposal action is taken which could be construed as illegal dumping.

A cover must be in place over the waste while it is being transported!

Recycling

Waste Minimization is one of NUWC Division, Keyport’s top priorities. Recycling is one tool to help reduce the quantity of waste produced on base.

The contract will specify responsibilities and procedures for recyclable waste produced while working on base. If the contract does not specify or is unclear, immediately notify the COR.

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It is important to note that in many instances where the DoN does not provide recycling services, the DoN may require monthly reports of what was recycled and what was wasted (land filed or disposed of as hazardous) within project contract submittals. If a Contractor Monthly Project Waste Summary Report (CMPWSR) is required by your contract, fill out the CMPWSR each month and turn the information in to the COR. If you have questions or concerns regarding recycling for your project, please request clarification from the COR.

Regulations vary on how waste must be managed prior to recycling, depending on the waste itself. The most common categories for recycling are:

1. Specifically regulated recyclable materials. These are recyclable materials regulated under their own respective sections of Washington State Administrative Code (WAC) 173-303 (e.g., spent lead-acid batteries).

2. Recyclable materials that are not regulated. These are materials that are not regulated prior to use or reuse (e.g. cardboard or paper).

3. Recyclable materials that are fully regulated. These materials are fully regulated up to the point when they actually enter the recycling process that recycles the material (e.g. chloroflurocarbons and anti-freeze).

Oftentimes, waste that is destined for recycling must still be controlled and managed as HW until the point at which the waste is reclaimed.

Kitsap County Public Works Solid Waste Division is an excellent resource for local recycling options and can provide guidance and information regarding recycling resources within Kitsap County.

http://recycle.kitsapgov.com/Pages/Home.aspx

Training Requirements

All projects that involve generation and management of HW at NUWC Division, Keyport are required to appoint a HW site manager and HW site manager alternate. The HW site manager and alternate receive detailed site-specific training on HW management procedures and requirements for working on base and are responsible for interfacing with the BEO to ensure HW management requirements are satisfied throughout the duration of the project.

NUWC Division, Keyport HW site manager/alternate training is provided by the BEO and will be conducted in-person. Contractors should contact their COR for scheduling HW site manager/alternate training.

NUWC Division, Keyport Environmental Contractor Guide http://recycle.kitsapgov.com/Pages/Home.aspx

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Polychlorinated Biphenyls (PCBs) Waste Program Manager NUWC Division, Keyport Code 1023, 360-396-2320

Program Summary

Since 1979, the EPA regulates the use, storage, disposal, and distribution in commerce of PCBs. The law for PCBs is the Toxic Substance Control Act (TSCA). Common equipment containing PCB’s includes electrical transformers and fluorescent light ballasts.

PCB Requirements

Light ballasts may or may not contain PCBs. If they are not labeled "No PCB" then they are assumed to contain greater than 50 parts per million (ppm) PCB and are regulated under the TSCA. Transformers should be labeled identifying their PCB content.

Discarded transformers, capacitors, or bushings containing PCBs at concentrations of 2 ppm or greater (except when drained of all free-flowing liquid) are regulated in Washington state as HW. Fluid, core, and core papers from these specific sources are also regulated in Washington as a HW when generated from the salvaging, rebuilding, or discarding of transformers, capacitors, or bushings.

Samples are required for materials that have been shown in the past to contain PCBs above the regulatory limit of 50 ppm. See Waste Management section for information on management requirements for PCB containing waste.

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Clean Water Water Program Manager, NUWC Division, Keyport Code 1023, 360-315-8571

Drinking Water Program Summary

Obtain a connection permit from the NBK Bangor Public Works department prior to making any connections or changes to the potable drinking water system. A connection permit is necessary even for small or temporary connections (e.g. connecting an ice machine, temporary connection to a fire hydrant, etc.).

Request approval for water connections per NAVBASEKITSAPINST 11300.1. Allow a minimum of 15 working days for processing. A Utility Connection/Disconnection Permit Request Form must be completed and provided to the COR for submission to the NBK Outage Coordinator at nbkbangpwdreqeusts@navy.mil.

Backflow preventer need/size/type will be determined by the base water shop; only the water shop is authorized to make this decision. Post installation inspections are required, and a report must be provided to NBK Bangor Public Works.

If making significant system changes (system extension, system improvement, capacity change, etc.)

permission from the Department of Health may be required. Contact the COR immediately if significant water system changes may be required.

Decommissioned wells or geotechnical borings drilled for a project shall be in accordance with

MINIMUM STANDARDS FOR CONSTRUCTION AND MAINTENANCE OF WELLS (WAC 173-160).

Stormwater Program Summary

The purpose of storm drains is to prevent flooding by conveying stormwater runoff to saltwater or stormwater facilities. All discharges going directly into surface waters such as Liberty Bay, Hood Canal, or streams and wetlands are strictly controlled, and no contaminants are authorized. Examples of prohibited discharges include all hazardous materials and wastes, petroleum products, solvents, detergents, wastewater, and contaminated ground water. Industrial wastewaters cannot be disposed of as stormwater and must be disposed of in accordance with HW regulations. Get approval for projects disturbing more than one acre before discharging any water anywhere!

Stormwater Program Requirements

Information you will need to know about your project regarding stormwater control:

Will there be any ground disturbing activity? Make sure to include not only the footprint of the project, but also staging areas, temporary trailers, parking, retention ponds, etc.

Will there be total ground disturbance greater than 1 acre?

Does the slope exceed 35% at any point within the project or will any work within the footprint take place on known unstable soils?

Will there be groundwater dewatering for foundations or other construction activity?

Will any hazardous material, waste, demolition debris, soil, open or leaky dumpsters, or any other potential pollutant be exposed to stormwater?

Is this a major renovation or construction project (> $5 million if renovation >

$750K if construction)? If yes, “Low Impact Development” (LID) must be considered in the design, or justification must be provided if LID is not utilized.

NUWC Division, Keyport Environmental Contractor Guide mailto:nbkbangpwdreqeusts@navy.mil

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Does the project add 2000 square feet or more of new impervious surface, convert 3/4 acre or more of native vegetation to landscaped area, or have land disturbing activities of 7000 square feet or more? If yes, have the 10 minimum requirements listed in Volume I of the Stormwater Management Manual for Western Washington been evaluated for applicability, and has a hydrologic analysis been conducted.

Does the analysis indicate a requirement for flow control and/or runoff treatment structures? Are these structures included in the project footprint?

Which water body will receive the project stormwater?

Stormwater Pollution Prevention Plan

Sites disturbing 1 Acre or More:

A Stormwater Pollution Prevention Plan (SWPPP) must be completed by the contractor and be approved by the COR prior to beginning construction activities. The SWPPP shall be prepared in accordance with the requirements outlined in the latest version of the Stormwater Management Manual for Western Washington, which can be found at the following link.

http://www.ecy.wa.gov/programs/wq/stormwater/manual.html

The SWPPP must be completed and approved prior to submitting the Notice of Intent (NOI) to EPA for the construction project. The NOI must be approved by EPA prior to commencing construction activities. Upon completion of construction, submit a Notice of Termination to the EPA.

Sites disturbing under 1 Acre:

When a site covers less than one acre, a SWPPP, NOI, and NOT are unnecessary; instead, the contractor is required to submit a brief statement and receive approval by the BEO regarding adequate controls prior to construction activity. This statement shall include:

Brief project description.

Total acreage disturbed.

Project supervisor and other points of contact.

Project drainage information.

Sequence of construction.

Stormwater Best Management Practices (BMPs) that will be applied to the site.

Site map showing where BMPs will be implemented.

Description/checklist of weekly inspections.

Hazardous materials handling and storage processes.

Practices for exposed soil coverage (in compliance with the requirements of the Stormwater Management

Manual for Western Washington).

Contact the BEO for questions regarding SWPPPs and environmental compliance.

Worksite Cleanup:

Keep the work site clean to minimize loss of accumulated debris into the storm drains. When dirt, surplus materials, solid waste, and dropped materials are allowed to accumulate, these materials can be washed into the stormwater system when it rains.

NUWC Division, Keyport Environmental Contractor Guide http://www.ecy.wa.gov/programs/wq/stormwater/manual.html

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Conduct weekly cleanliness inspections of outdoor work and storage areas. Clean work areas as necessary to maintain control of potential pollutants.

Material Storage and Handling:

Handle and store materials using methods that reduce or eliminate exposure to rainfall. Minimize the potential for spills. Protect containers storing liquids (e.g. fuels, paints, and solvents, etc.) from the weather, by placing inside a covered area (or under a tarp) in a secure location, away from storm drains.

Proper protection methods require placing materials inside secondary containments. Use rubber mats over storm drains when loading and unloading supplies from trucks and trailers. Contractors are responsible for establishing the secondary containments if none exist. Secondary containment is an impervious basin compatible with all materials stored in the basin, and large enough to contain 100% of the volume of the single largest container, or 25% of the volume of all containers stored.