PAFB_Final_2013_HWMP.pdf

HAZARDOUS WASTE MANAGEMENT PLAN

For

Peterson Air Force Base EPA ID No.: CO9571924191

Colorado Springs, Colorado 80914-2370

Prepared By:

CEIE

580 Goodfellow Street Peterson AFB, Colorado 80914-2370

Peterson AFB Hazardous Waste Management Plan

Table of Contents

1.0 Administrative…………………………….…………………………………………………….5

1.1 Implementing Base Instruction…………….……………………………………………..5

1.2 OPSEC Security and Administrative Instruction gram….……………………………

1.3 Information and Emergency Contacts………………………………………………..…..5

1.4 Record of Changes….………………………………………………………………

1.5 Record of Annual Review ………………………………………………………….…..12

2.0 Introduction…………………………………………………………………………………...13

2.1 Background introduction….…………………………………………………………….13

2.2 Scope of the Hazardous Waste Management Program….……………………………...13

2.3 Generation of Hazardous Waste……………………………………………………...…14

2.4 Compliance Procedures…………………………………………………………….…...15

2.5 References………………………………………………………………………….…...15

2.6 Abbreviations and Terms………………………………………………………….……16

3.0 Responsibilities…………………………………………………………………………...…...17

3.1 Tasked Organizations………………………………………….………….…………….17

3.2 Specific Responsibilities…………………………………………….……………….…17

4.0 Hazardous Waste Stream Inventory and Locations……………………………...………...24

4.1 Hazardous Waste Locations…………………………………………….……………

4.2 Hazardous Waste Stream Inventory………………………………….…………….…...24

5.0 Waste Analysis Plan…………………………………….……………………………….……27

5.1 Purpose of the Waste Analysis Plan…………………………………….…………..…..27

5.2 Waste Analysis at Peterson AFB…………………………………………….…….…...27

6.0 Management and Operating Procedures………………………………………………...….30

6.1 General………………………………………………….………………………………30

6.2 Accumulation Point and Site Specifications……………….………………...….……...30

6.3 Waste Identification……………...……………………………………….……….……31

6.4 Packaging and Containers……………………………………….…………………….. 31

6.5 Marking and Labeling…………………………………………………………………..32

6.6 Shipping Labels…………………………………………………………………………32

6.7 Accumulation…………………………………………………………………………...37

6.8 Handling Wastes………………………………………………………………..………41

6.9 Inspection Program……………………………………………………………..………42

6.10 Hazardous Waste Inventory…………………………………………………….……... 42

6.11 Waste Turn In To CEIE………..……………………….………………………..……...43

6.12 Record Keeping....……………………………………….………………………..…….45

7.0 HW Manager Management and Operating Procedure………………….……………...….46

7.1 Shipping Markings and Labels……………………………….………….………….…..46

7.2 Storage: Central Accumulation Point…………………………………….………..…...46

7.3 Internal Site Inspection Program……………………………………….………..…

7.4 Central Accumulation Site Inventory………………………….……………………..…50

7.5 Waste Turn In Through DLA Disposition Services.…………………….………….…..50

7.6 Shipping HW………………………………………………………………………..…..51

7.7 Reporting……………………………………………………………………….……….52

7.8 Establishing Accumulation Points………………………………………....…………...53

8.0 Used Oil Management……………………………………………………………………..….55

9.0 Recoverable Fuel…………………………………………………………………………

10.0 Training……………………………………………...……….………………………………..57

10.1 Training Scope……………………………………………………………………….…57

10.2 Training Requirements…………...……………………………………………….…….57

10.3 Training Frequency………………………………………………………………….….58

10.4 Peterson AFB Hazardous Waste Training Program………………….…………………58

10.5 Air Force Hazardous Waste Management Training Program……….….………………59

11.0 Emergency Response Preparedness…………………………….………………………

11.1 Contingency Plan for Waste Generating Activities………………..…………………...62

11.2 Response Actions…………………………………………………..…………………..62

12.0 Pollution Prevention ………………………………………………………………………….63

12.1 Waste Minimization Plan…………………………………………………………….…63

12.2 Scope of the Pollution Prevention Plan………………………………………………

Appendix A Abbreviations and Terms………………………………………………………

Appendix B Waste Stream Inventory…………………………………………………………..78

Appendix C Satellite Accumulation Managers…………………………………………….…..86

Appendix D Hazardous Waste Accumulation Maps.…………………………………….…….88

Appendix E Sample Forms…………………………………………………………………

Appendix F Instruction for Completing DRMS Form 1930……………………………….…101

Appendix G Instructions for Waste Turn in Form……………………………………………106

Appendix H Record Keeping Requirements………………………………………………….107

Appendix I HW Notification Form …………………………………………………………..108

Appendix J Distribution List……………………………..……………………………….…..110

Appendix K DOT Manifest Training Certificates…………………………………………….113

Appendix L Waste Analysis Plan …………………………………………………………….120

Appendix M Hydrocarbon Mitigation SOP and Response Checklist ....……………………..177

1.0 Administrative

1.1 Implementing Base Instruction

Implementation of the comprehensive hazardous waste management program mandated by the Resource Conservation and Recovery Act (RCRA) requires maximum cooperation of all activities on Peterson Air Force Base (PAFB). It is the responsibility of the Wing Commander to ensure compliance with all RCRA requirements for PAFB and to notify and to report to the Environmental Protection Agency (EPA) or the State as required for all installation activities, including tenants. The individual base operational units (generators) are accountable for conducting their activities in accordance with this plan. Those base units, including supporting Defense Logistics Agency Disposition Services (DLA) activities and tenant activities, will provide necessary documentation to the Wing Commander through the Environmental Safety Occupational Health Committee (ESOHC) to provide the reports required by EPA or the State and ensure compliance with RCRA regulations at the facility. Refer to Implementing Base Instruction memo.

1.2 OPSEC Security and Administrative Instructions

1.2.1 Title: The long title of this document is the Peterson AFB Hazardous Waste Management Plan (HWMP). The short title, and the one that will be referenced throughout this document is HWMP.

1.2.2 OPERATIONAL SECURITY OPSEC: This plan is not classified, but it is considered FOR OFFICIAL USE ONLY (FOUO). It contains full spectrum physical threat operations, procedures, and tasking. Therefore, all personnel using or handling this document must exercise deliberate and concerted efforts to ensure it is disseminated only on a “need-to-know” basis. Unauthorized or inadvertent disclosure may result in unacceptable degradation of disaster response capabilities.

1.2.3 Responsibilities: CEIE is the office of primary responsibility. This instruction is applicable to all personnel handling hazardous and non-hazardous waste. Tasked organizations are authorized to extract and reproduce those portions of the plan that are essential in the accomplishment of necessary planning and in the preparation of supporting documents and reports.

1.2.4 Reviews/Changes: Plan will be reviewed and changes incorporated annually.

1.2.5 Distribution: This plan will be distributed to those organizations shown on the distribution list in Appendix K. The plan will be controlled in accordance with established United States Air Force (USAF) procedures for unclassified documents.

1.3 Information and Emergency Contacts

1.3.1 On Base Emergencies

Fires, explosions or spills that may cause a fire – Base Fire Department 911 Spills of hazardous waste or hazardous substances - Base Fire Department 911

1.3.2 Emergency Assistance and Information

On-Base Assistance and Information

Hazardous Waste Manager 556-7328 Bioenvironmental Engineer 556-7721 Base Civil Engineer Service Call (Facility Maintenance) 556-4030 Emergency Medical Services (From Base non-resident phone) 911

Ground Safety 554-5649

Security Forces 556-4805 Public Affairs 556-5185 Contracting Office 554-5250 Staff Judge Advocate 556-4871

DRMO, Colorado Springs Hazardous Waste and PCB 526-9680 Used Oil 526-9582

HAZMART

Office 556-4429 Yard 556-6513 Base Fuels Management 556-8461 Unserviceable Processing Center 556-4446

For Air Force Major Command (MAJCOM)

Release Reporting 554-6939 Report of Regulatory Inspection and Notices of Violation 554-6939 Hazardous Waste Information 554-3846

Off-Base Assistance and Information

Hazardous Waste Information Hotline 800-424-8802 National Response Center 800-424-8802 RCRA/Superfund Hotline 800-424-9346 EPA Region 8 Response Center 800-227-8914 EPA Region 8 RCRA Compliance 303-312-6051

EPA Emergency Planning & Community Right-to-Know Information Hotline 800-677-9424

Colorado Department of Public Health and the Environment (CDPHE) Hazardous Materials and Waste Management Division 303-692-3300 CDPHE Emergency Response Line 877-518-5608

CHEMTREC 800-424-9300

Local Emergency Response Commission 574-7057

1.4 Record of Changes

Change

Description Date Org

1 Administrative organization symbol change from CEANQ to

CEIE.

19-Nov-12 CEIE

2 2.2.1 Add as last sentence of paragraph one: PAFB is part of Air Force Space Command; however this hazardous waste management plan incorporates the individual EPA ID number, waste streams, SAP, management policy and practices, and disposal documentation/requirements for PAFB only. Each Air Force Installation under the Space Command is required to prepare, implement, and train their personnel based on generator status requirement and the requirements of AFI 32-7042.

19-Nov-12 CEIE

3 2.4 Add as last sentence of paragraph: A copy of the WAP is attached to this plan as Appendix K.

19-Nov-12 CEIE

4 Throughout document change MSDS to Material Safety Sheet (MSS) 19-Nov-12 CEIE 5 Change throughout document from DRMO to Defense Logistics Agency

(DLA) Disposition Services

6 3.2.6.5 Deleted sentence: Implements Air Force Occupational and Environmental Safety, Fire Protection, and Health (AFOSH) Program.

4-Dec-12 21 MDS/

SGPS

7 Section 3.2.14 Add as last sentence: There are three persons trained to sign manifests for Peterson AFB. Documentation of this training can be found in Appendix I.

19-Nov 12 CEIE

8 3.2.3.8 Revise sentence to : Maintains and operates the Hazardous Waste Central Accumulation CAP at Bldg 685

19-Nov-12 CEIE

9 Section 5.2.1, Pg 1 Add: PAFB will re-evaluate waste streams as a BMP for Pollution Prevention initiatives and to ensure waste stream accuracy.

19-Nov-12 CEIE

10 Add bullet to Section 6.3: 6.3.5 Any Medical or Pharmaceutical Waste must have a waste determination conducted prior to being shipped off Base for credit returns. An annual Pharmaceutical Waste Determination will be conducted by CEIE based on 21 MDG wholesalers‟ purchase inventory. It is the responsibility of 21 MDG to obtain wholesalers‟ purchase inventory in order for CEIE to make waste determination.

21 MDG generates acute warfarin waste at both pharmacies. Peterson AFB will determine weight of the residue only, rather than the weight of the entire empty container for generation status requirements. Based on State Residue Determination Guidance Letter, each bulk warfarin empty container will weigh 1 gram of acute waste residue. Total weight of residue equals 1 gram multiplied by number of empty containers. The weight of residue is only for the empty containers. When expired pills are turned in, both the weight of container and the pills must be used to determine weight of acute waste. Grand total weight of acute waste will be the weight of the residue and the weight of expired product/containers.

19-Nov-12 CEIE

11 Section 6.5.1.1, Pg 3, last sentence of paragraph will read: CEIE will ensure that the transportation contractor will affix a yellow hazardous waste label (Figure 6-2) to the container prior to shipment off the installation.

19-Nov-12 CEIE

12 Section 6.8.6, Revise sentence to read: A bonding wire may be used to connect the container you are pouring from to the container you are pouring into when transferring flammable liquids into containers to prevent sparks

19-Nov-12 CEIE caused by the build-up of static electricity during pouring operations.

Section 6.11.3.2, Add to first bullet as last sentence: Each driver that brings hazardous waste to 685 must be using a government vehicle and have a current government driver‟s license.

14 Section 8.0 Add the following paragraphs: Based on State Pollution

Prevention Initiatives, all used oils should be recycled to the fullest extent possible. The commercial bill of lading for all used oils shipped off base must be supplied to CEIE. Additionally, the initial one-time-notice and Land Disposal Restriction (LDR) notice must be filed with the transporter/recycler.

Per the Federal Acquisition Regulations (FAR) and Green Product Substitution, PAFB will require shops using oil in their mission to buy re-refined oil as long as it meets the required mil-spec for the intended user.

This reclaimed oil product is available at a greatly reduced price through Defense Supply Program. The continual reuse of re-refined oil through a qualified “Closed Loop” recycling vendor will reduce the government‟s demand on a foreign virgin supply, and increase our pollution prevention “Net Zero” metrics.

All proposed shipments of recyclable products or hazardous waste must have approval by CEIE prior to off-base movement.

Used oil management requirements are contained in the “Spill Prevention Control and Counter Measures Plan” maintained by CEIE.

It is a Peterson BMP to hot drain all fuel and oil filters and recycle the metal filters. Per 6CCR 1007-3, Section 261. 6(a)(3)(ii). This RCRA exemption requires the management of all scrap metal, including shavings, drillings, lead solder and larger metal scraps, as recyclable scrap metal. All scrap metal containers must the labeled as “Scrap Metal for Recycling”.

Section 9.0 Revise to read: Fuel should be managed in such a manner that it can be recycled as recoverable fuels. This requires diligence on the part of shop users to ensure that other non-petroleum based products are not mixed into the fuel to cause contamination. Of particular concern are the solvent or halogenated cleaning products. No characteristics or listed hazardous wastes should be mixed with fuel that is being recovered for fuel blending or used for thermal recovery. Any fuels purged from equipment should be stored in clean bowsers or mobile tankers and replaced into equipment when repairs are complete. All non-contaminated recoverable fuels will be reclaimed through an off-base vendor.

PAFB HWPM will create all required LDR forms to ensure all DOT/RCRA requirements are meet. Any shops needing recoverable fuel collected and shipped for reclamation should coordinate with 21 CEIE personnel to ensure proper documentation is retained with the files at CEIE.

Any waste fuel or liquid containerized spill fuels (contaminated) will be managed and shipped through DLA Disposition Services as hazardous waste on the standard hazardous waste manifest.

Based on the 20 July 2010 SOP (See Appendix L), FM 186-2 Hydrocarbon Mitigation Chemical waste minimization product is to be used for all petroleum spills of 5 gallons of less. FM-186-2 should be used on a one-to-one basis and swept around to allow chemical bonding of the benzene to provide complete waste mitigation. FM 186-2 soaked rags can be disposed of as solid waste per waste analysis numbers 458 and 523.

Peterson AFB has made a determination that no terne plated fuel filters are utilized on base because terne plated filter manufacturing process was ceased in 1976 and PAFB owns no equipment from that time frame.

16 Section 11.1, Pg 1 Revised to: If PAFB becomes a LQG a separate Hazardous Waste Contingency Plan has been created and maintained to fully address the contingency, preparedness and prevention requirements of 6 CCR 1007-3, Section 262.32 (d) and 40 CFR 265 Subparts C and D.

PAFB hazardous material emergency response is covered within the 21 CES Readiness, Contingency Response Plan. Also the PAFB SPCC Plan covers emergency procedures and evacuation route. Each shop using HazMat should create an Emergency Response Plan and post the evacuation route map. Emergency response activities relating to hazardous waste spills, fires or explosions involving hazardous waste shall be in accordance with the Hazardous Waste Contingency Plan.

19-Nov-12 CEIE

17 Section 12.0 Add the following bullets to the Peterson P2 Initiatives:

All shops requiring rags for their mission will use leased rags through the 21 CES Continuous Use Rag Project Contract to reduce both solid waste and hazardous waste disposal costs.

Peterson AFB initiated the first Household Medication Take Back event in 2012.

All CEIE personnel are members of the Cross Functional Team within the EMS Program designed to continually monitor and improve/eliminate environmental impacts.

Peterson has quarterly Water Working Group Team Meeting to ensure all funded projects are in compliance with all Clear Water Act requirements.

Environmental design specifications are included into all government funded contracts to ensure environmental impacts will be addressed, eliminated or mitigated.

All new base personnel participate in Environmental Awareness Training provided monthly at the New Comers Briefings.

All base personnel have access to annual Environmental Awareness Training to include RCRA Awareness, Storm Water Training and Spill Prevention Control & Countermeasure training.

CEIE is implementing „single source‟ recycling to make recycling easier and more efficient.

Peterson AFB annually participates in the Tree City USA program to ensure a continual and healthy Urban Forestry Program.

Peterson has a material „Free Issue Program” to increase our capability to re-distribute excess hazardous materials.

Peterson uses the EESOH-MIS Program to advertise & re-distribute hazardous materials into the DOD wide „Global Access System‟.

Peterson AFB annually participates in the National Recycle and Arbor Day events to increase awareness in resource management practices.

Peterson AFB has a quarterly Hazardous Material Working Group.

19-Nov-12 CEIE

18 Section 10.5.1, Revise sentence to read: Level I: Basic Hazardous Waste Training is required for all personnel and their supervisors who are assigned

11-Dec-12 21 SW/

PA

duties as the facility manager or hazardous material monitor, those using hazardous material or are handling fluorescent light bulbs (any type of light bulb), batteries, or products in aerosols. These items are considered Universal Waste (UW). The facility manager manages the UW and receives the Facility Managers training through CEIE. The Facility Managers training covers management of Universal Waste.

Administrative change organization symbols to CEIE Appendix A, Terms - MSDS to MSS Appendix B Insert FY 12 Waste stream inventory Appendix C - TA Bldg 121 Closed June 12 302 Bldg 210 Fuel Cell Closed Dec 2011 302 Bldg 216, change primary to Nicholas Griffin and replace William Harris with Charlie Huffman as alternate Bldg 959 Pharmacy change primary to Calvin Cummings Bldg 1281 change primary to Daniel Tisdel Bldg 2012 ADL, change primary to Michael Holmes Bldg 2017 East Pharmacy, change primary to Nicholas Xenos Appendix D, Map - Remove SAP 121, 210

19-Oct-12 CEIE

20 WAP Table 1.1 - delete Cheyenne Mountain WAP Section 1.6.2 .e. - Change sentence to read: Submit sample analysis results of new waste streams (taken by the Sampling Contractor) to the offsite TSD facility or DRMO for verification of characterization.

WAP Section 2.1 Delete:

Specifies and monitors the level of personnel protective equipment worn by personnel that handle or are exposed to hazardous waste.

Conducts annual surveys of waste storage facilities to assess compliance With applicable worker and environmental protection requirements.

Add in place:

- BE personnel perform occupational and environmental health (OEH) risk assessments of work processes.

- BE recommends/approves all respiratory protection devices and shall be consulted on all respiratory protection required for specific shop activities, if required.

- PPE, when required, shall be selected to protect against the identified or potential hazards. Generators must contact BE for further assistance.

- Generators will coordinate process and waste changes with BE to determine any occupational or environmental health risk.

4-Dec-12 21

AMDS

/SGPB

21 WAP Section 3 change MSDS to MSS WAP Table 5.1 Waste stream Analyzed in FY12 WAP Add FY12 Waste Stream Inventory Delete Section 3.2.6.5

5-Dec-12 21

AMDS/

SGPB

22 Section 8.3 Sample Documentation last sentence revise to : The Sampling Contractor initiates the sample chain-of-custody record in the field at the time samples are collected and documents sample collection activities, including:

5-Dec-12 21

AMDS/

SGPB

1.5 Record of Annual Review

REVIEWED BY DATE

REVIEWED

REMARKS

Environmental Leadership Council Feb. 2006 Review comments will be incorporated March 2006

ESOH Council Oct 2007 Review comments will be incorporated Dec

ESOH Council Oct 2008 Review comments will be incorporated Dec

ESOH Council Oct 2009 Review comments will be incorporated Dec

ESOH Council Nov 2012

(Annual changes are available for review at the CEIE, Building 1324)

2.0 Introduction

2.1 Background Introduction

2.1.1 Objective: The United States Air Force is committed to proper management of hazardous wastes generated on its installations. The primary objective of the HWMP is to provide non-hazardous and hazardous waste program managers the essential tools for effective management. It further establishes operational procedures, tasks, and other requirements for all tasked organizations.

2.1.2 History: With the passage of the Clean Air and Water Acts in the early 1970s, problems associated with solid and hazardous waste disposal were unwittingly increased. Hazardous materials that were previously discharged to streams and rivers prior to the Clean Water Act were disposed of in landfills, lagoons, and underground injection wells. To further complicate this situation, the unforeseen legacy of America's industrialization and chemical revolution was beginning to manifest itself in the form of Love Canal and other old waste disposal sites.

To close the loop of environmental regulation, the RCRA of 1976 was enacted to deal with the ongoing problems of hazardous waste management. This act mandated a system of management from the generation of waste materials to final disposal or "cradle-to-grave.” RCRA sets up standards for those who generate, transport, store, treat, and dispose of hazardous waste. These generator standards ensure proper record keeping and reporting; the use of a manifest system to track shipments of hazardous waste;

the use of proper labels and containers; and the delivery of the waste to properly permitted treatment, storage, and disposal facilities (TSDF).

2.1.3 Effective Dates: On 19 May 1980, the EPA published the Hazardous Waste Management System rules of Subtitle C of the Solid Waste Disposal Act, as amended by RCRA of 1976. This act directed the Environmental Protection Agency (EPA) to promulgate regulations to protect human health and the environment from improper management of hazardous waste. The effective date of these far-ranging regulations was 19 November 1980. RCRA was again amended in 1984. The amendments require increased management of hazardous waste by all organizations on PAFB. The EPA has delegated RCRA implementation to the state of Colorado, which developed its own program to implement RCRA within the state. The procedures of this plan will be used to comply with Federal and state legislation and regulations. Plan revisions shall reflect changes in either level of hazardous waste management laws and regulations. Each revision to this will become effective immediately upon distribution unless otherwise noted therein.

2.2 Scope of the Hazardous Waste Management Program

The United States Air Force and PAFB are committed to properly managing hazardous wastes that are generated on their installations. The primary objective of this document is to provide a management plan that gives non-hazardous and hazardous waste program managers the essential tools for effective management

2.2.1 Applicability to PAFB: This plan applies to all facilities, including tenant organizations, generating non-hazardous and hazardous waste (HW) on PAFB. This plan deals with key points in implementing the complex area of non-hazardous and hazardous waste management required by RCRA and is enforced by the U.S. EPA at Federal facilities such as PAFB. Subject to these regulations, PAFB is required to identify and evaluate all processes that produce solid waste. An evaluation must then be made to determine if the solid waste material is a hazardous waste and a program for storage, handling and disposal of hazardous waste must be developed. Peterson AFB is part of Air Force Space Command;

however, this hazardous waste management plan incorporates the individual EPA ID number, waste streams, SAPs, management policy and practices, and disposal documentation/requirements for PAFB only. Each Air Force Installation under the Space Command is required to prepare, implement, and train their personnel based on generator status requirement and the requirements of AFI 32-7042.

Federal facilities are not exempt from the requirements of this law. In addition, PAFB is subject to compliance inspections by either the Colorado Department of Public Health and Environment (CDPHE) or EPA with the potential for discrepancies to result in Notices of Violation (NOV), civil fines and/or criminal prosecution. This plan covers the control and management of hazardous materials from the point they become hazardous wastes at the point of generation to the point of ultimate disposal. The scope of the plan is implementation of the EPA's philosophy of “cradle to grave” management and control of hazardous waste.

2.2.2 Applicability of State Requirements: The management of hazardous waste is governed by Federal law as promulgated by the EPA and managed in Colorado by the CDPHE. The state is required to have laws and regulations at least equal to, or in some circumstances more stringent than, Federal policy. This plan is designed to address mandatory requirements of the state of Colorado Hazardous Waste Management regulations. PAFB is not exempt from state regulations to implement RCRA requirements.

2.2.3 Definition of Hazardous Waste: A hazardous waste is any material that is detrimental to human health or poses a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of or otherwise managed. For a material to be a hazardous waste, it must first be a solid waste. A solid waste is generally any discarded material, including liquids. Solid wastes may then have certain chemical and physical characteristics such as , reactivity, corrosivity or toxicity that make them hazardous wastes. A material may be also be classified as hazardous waste if it has been determined the particular material is hazardous and is listed as such in the Code of Federal Regulations (CFR) or the Colorado Code of Regulations (CCR).

The federal law that details requirements for the identification of hazardous waste is Title 40, of the Code of Federal Regulations, Part 261 (40 CFR 261).

The state law which details requirements for the identification of hazardous waste is 6 Colorado Code of Regulations (CCR) 1007-3, Section 261.

2.3 Generation of Hazardous Waste

An organization that uses a process that produces a hazardous waste is called a "generator.” The use of the material from product to waste is the "waste stream." Typical generators include production services such as auto repair areas, photographic processes, graphics and reproduction services. Discarded hazardous material, even if unused, becomes hazardous waste. Commercial retail products, such as the Base Exchange pesticide products, may also become hazardous waste when spilled or discarded.

2.3.1 Considering total production of all waste streams on base, PAFB can be classified by regulatory agencies as either a "small quantity generator" or a "large quantity generator." A small quantity generator produces 100 - 1,000 kilograms (kg) (which equals 220 - 2,200 pounds or 26.5 - 265 gallons or one-half to five 55-gallon drums) of hazardous waste per month or less than 1 kg of acute hazardous waste per month. A large quantity generator produces anything over these amounts. If any of these amounts are exceeded for only one month out of the year, the base will be considered a large quantity generator (LQG) for the entire year and subject to the large quantity generator requirements.

2.3.2 Generators of hazardous waste must notify the state regarding their generator status and the state will provide an EPA identification number. PAFB EPA ID number is: CO9571924191.

2.3.3 Classification status affects compliance requirements of the regulatory agencies. These requirements are not addressed as part of this plan based on current status. It is advantageous for financial and regulatory reasons to generate the least amount of hazardous waste as possible.

2.3.4 A waste minimization program is a required part of a hazardous waste management program.

Organizational generators must make every attempt to minimize production of hazardous waste.

Quantities and frequency of materials turned in for disposal will be routinely evaluated by the ESOH Council. Organizations may be required to investigate alternative products or change processes.

2.4 Compliance Procedures

The basic procedural requirements for the operation of a hazardous waste management program are classification or identification of waste streams and products, and determining whether the material is classified as a hazardous waste. The PAFB Waste Analysis Plan (WAP), which is prepared by the CEIE, describes hazardous waste determination and classification in detail. A copy of the WAP is attached to this plan as Appendix K.

2.4.1 CEIE will be responsible for classifying waste.

2.4.2 Testing of Materials. Laboratory analysis of materials must be made if characteristics shown above are unknown for the material.

The Regional Sampling Contractor will perform these services.

2.4.3 User Knowledge. If a specific material and generation process is known to the generator and a Material Safety Sheet (MSS) is available for the material, user knowledge may be used to determine waste characteristics. Adequate documentation is essential for relying on user knowledge.

2.5 References

Title 40 of the Code of Federal Regulations (CFR), Parts 260-279 contains Resource Conservation and Recovery Act (RCRA) regulations.

Colorado Hazardous Waste Regulations, 6-Colorado Code of Regulations (CCR) 1007-3 contains the state‟s hazardous waste regulations.

Title 49 Code of Federal Regulations (CFR), Parts 100-199 contains Department of Transportation (DOT) regulations. DOT regulates the proper shipping, labeling, marking, and packaging of wastes.

Reference to the Emergency Planning and Community Right-to-Know Act (EPCRA) is Title III of the Superfund Amendments and Reauthorization Act (SARA) of 1986.

Title 29 Code of Regulations (CFR), Parts 1900 to 1910 contain Occupational Safety and Health Act regulations.

Extremely hazardous substances are identified in the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980, as amended.

Colorado Department of Public Health and Environment, Hazardous Waste Guidance, Satellite Accumulation for Small and Large Quantity Generators of Hazardous Waste, Feb 1998.

Guide to Generator Requirements of the Colorado Hazardous Waste Regulations, Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division, Second Edition, March 1995.

This plan conforms to the following Air Force Regulations:

AFI 32-2001, Fire Protection Operations and Fire Prevention Program Air Force Occupational Safety and Health Standards (AFOSH) Air Force Hazardous Waste Management Policy, 28 June 2008 AFI 32-7042, Waste Management

2.6 Abbreviations and Terms

Refer to Appendix B for Abbreviations and Terms.

3.0 Responsibilities

3.1 Tasked Organizations

Responsibilities for implementing this plan are distributed throughout base organizations that generate, treat, accumulate, store, transport, turn-in, monitor, dispose of, or respond to incidents involving non-hazardous and hazardous waste. Base compliance with Federal, State and local hazardous waste laws and regulations is the responsibility of the Wing Commander through the Base Environmental Safety Occupational Health Committee (ESOHC). The following organizations are tasked under this plan:

3.2 Specific Responsibilities

3.2.1 21st Space Wing Vice Commander (ESOHC Chair):

Responsible for management of hazardous waste at PAFB, to include providing continuing support for the safe management of hazardous wastes.

3.2.1.1 Ensures management of hazardous waste on PAFB complies with applicable portions of 40 CFR Parts 260-279 and 6 CCR 1006-3, Parts 260-279.

3.2.1.2 Ensures HWMP is reviewed at annually.

3.2.1.3 Ensures all generating organizations comply with the HWMP.

3.2.1.4 Ensures all hazardous waste manifests are signed. There are three persons trained to sign manifests for Peterson AFB. Documentation of this training can be found in Appendix I.

3.2.1.5 Establishes and maintains an active program to survey the use of hazardous material and the generation and disposal of hazardous waste.

3.2.1.6 Establishes an active program to minimize hazardous waste generation.

3.2.1.7 Ensures all personnel handling hazardous materials receive required hazardous material training.

3.2.1.8 Ensures host and tenant organizations on the installation comply with RCRA and state regulations.

3.2.1.9 Ensures all enforcement actions are resolved quickly.

3.2.2 The Base Civil Engineer (21 CES/CC)

3.2.2.1 Serves as OPR for developing and implementing the hazardous waste management plan, including coordination of emergency response activities.

3.2.2.2 Assigns adequate manpower to the environmental quality function for monitoring hazardous waste activities, including training, inspections, report preparation, and record keeping.

3.2.2.3 Ensures hazardous waste management training is provided annually.

3.2.2.4 Immediately consults the Staff Judge Advocate and HQ AFSPC when notified of an inspection, notice of noncompliance or violation, compliance order, hazardous material or hazardous waste-related fee or assessment from any federal, state or local regulatory agency or request for monitoring data.

3.2.2.5 Is the Second Alternate On-Scene Coordinator for emergency response.

3.2.3 Installation Management Flight Hazardous Waste Manager (CEIE)

3.2.3.1 Manages the base hazardous waste program.

3.2.3.2 Evaluates and classifies waste streams. Refer to Appendix C for the waste stream inventory, which identifies the type of HW, where it is generated, and the quantities that are generated. Waste stream evaluations are used to assist generating units, activities, and organizations in the identification of their HW. Any inquiries concerning the identification of HW should be directed to CEIE at 556-7328.

3.2.3.3 Updates Hazardous Waste Management Plan and Waste Analysis Plan.

3.2.3.4 Conducts or coordinates hazardous waste management training for all base personnel who handle or who may otherwise be involved in the management of hazardous waste.

3.2.3.5 Signs hazardous waste manifests, prepares hazardous waste reports, and compliance documentation as required by EPA, state regulatory agency, and Air Force instructions. (Note:

Individuals in CEIE who have current training outlined in 49 CFR 172.704 may sign manifests in the absence of the Hazardous Waste Manager.) PAFB has a total of three individuals who can sign the manifest.

3.2.3.6 Performs hazardous waste management site visits and maintains records of the site visits.

3.2.3.7 Coordinates with Federal, state, county, and city authorities on hazardous waste management procedures.

3.2.3.8 Maintains and operates the Hazardous Waste Central Point Accumulation CAP at Bldg 685.

3.2.3.9 Ensures designated Satellite Accumulation Points are properly managed.

3.2.3.10 Coordinates with the DLA Disposition Services for the disposal of hazardous waste and material. This includes ensuring waste is weighed for all disposal actions when required by DLA Disposition Services.

3.2.3.11 Maintains a written operating record. The following information will be recorded as it becomes available and will be perpetually maintained until the event of base or facility closure:

Facility layout plan.

Location of each non-hazardous and hazardous waste satellite accumulation point (SAP).

Records and results of waste analysis and trial tests.

Summary reports of all incidents, including exercises that require implementing the contingency plan.

Records and results of inspections.

3.2.3.12 Provides all applicable records to representatives of the EPA or Colorado who are duly designated by the Administrator.

3.2.3.13 Maintains a routine liaison with HQ AFSPC, EPA and state regulatory agencies in regard to hazardous waste inspections, rule interpretation, and problem resolution.

3.2.3.14 Maintains training records. Records of former employees will be retained for 3 years from the last day the person worked. All other training records will be maintained permanently.

3.2.3.15 Ensures storage of hazardous waste does not exceed 180 days for small quantity generator status or 90 days for large quantity generator status. (Note: Hazardous waste can be stored at Bldg 685 for up to 270 days if final disposal facility is more than 200 miles away).

3.2.3.16 Coordinates with generation point managers and accumulation point and site managers, Fire Department, Bioenvironmental Engineering (BE) and Ground Safety on location of hazardous waste accumulation sites.

3.2.3.17 Ensures that waste is transported safely per DOT regulations and only government vehicles are used to transport waste on base.

3.2.3.18 Through delegation from the Mission Suport Group (MSG), the installation Hazardous Material Management Plan (HMMP) team establishes and implements procedures for HM reduction, recycling, reuse, or shelf-life control, in order to minimize the generation of HW, AFI 32-7086, Section 2.10.1.3).

All hazardous material Facilities are required to participate, see AFI 32-7086, Section 2.3.1. The HazMarts ensure all attempts to reissue or classify hazardous materials are conducted prior to turn-in as HW, AFI 32-7086, Sections 2.4.6 & 2.10.1.3. The EESOH-MIS Global Access advertisement function creates yet another method of re-distribution of still useable materials. Based on HazMart„s expertise of material inventory & rotation functions, will help determine advertisement length of all HM. HazMarts will advertised “common use items” for 6 months and process specific (not commonly used be the major populace) will be held for advertisement for 3 months. During the advertisement period, the HM will be housed within organization‟s HazMart. HazMart will advertise these materials products through 1) Base Free-Issue and 2) Re-distribute to other installations through EESOH-MIS Global Access. Both advertisement actions shall be accomplished simultaneously, giving Space Command installations priority over Global Issue. 3) When both reuse methods have been exhausted, and as a last resort DLA (formerly DRMO) will accept the materials as HW through the HM/HW shared functionality within EESOH-MIS.

Within the HM tracking, the HazMarts will use the „Inventory Disposition Tab‟ to reach the “Request for Disposition” (RFD) form to waste out all time exhausted HM. The Fort Carson DLA Disposition Services Program does not offer the Re-Utilization, Transfer, and Donation Services for HM, therefore, the RFD process will only be used with the approval of the Hazardous Waste Program Manager (HWPM) for declaring HW. Material users will provide the HazMart the manufacturer‟s MSS to accompany the material for final waste disposal to HWMP.

3.2.3.19 The Regional Sampling contractor will collect samples for hazardous waste characterization and forwards them to an EPA or Colorado certified Laboratory for analysis in accordance with the sampling and analytical requirements specified in EPA Publication SW-846, 6 CCR 1007-3 (264.13 (b) 2), and the PAFB Waste Analysis Plan.

3.2.3.20 The Regional Sampling contractor will forward analytical results to the appropriate generating activity and CEIE.

3.2.3.21 The Regional Sampling contractor will assists base generating activities and CEIE in interpretation of analytical results.

3.2.4 Supply (21 LRS/CC)

3.2.4.1 Makes all attempts to reissue or classify hazardous materials being turned in by base organizations as usable products to minimize materials becoming hazardous waste.

3.2.4.2 Provides a listing of "hazardous materials issued" to the BE to ensure proper Personal Protective Equipment (PPE) has been identified for processes which utilize hazardous materials.

3.2.5 Contracting (21 CONS/CC)

3.2.5.1 Reviews all contracts to verify provisions are made for RCRA regulations.

3.2.6 Bioenvironmental Engineering (BE) (21 AMDS/SGPB)

3.2.6.1 Serves as technical point of contact for workplace health-related items.

3.2.6.2 Reviews workplace industrial processes and practices to evaluate personnel exposures and assess compliance with applicable Occupational and Environmental Health requirements.

3.2.6.3 Performs chemical authorization reviews and approvals as a member of the Enterprise Environmental, Safety and Occupational Health – Management Information (EESOH-MIS) team.

Specifies personal protective equipment to be worn by personnel occupationally exposed to or who may otherwise manage hazardous waste.

3.2.6.4 Specifies personal protective equipment to be worn by personnel occupationally exposed to industrial chemicals.

3.2.7 Public Affairs (21 SW/PA)

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

3.2.7.2 Assists the On-Scene Coordinator (Mission Support Group Commander) during situations involving hazardous waste incidents by keeping interested news media and the public aware of events and curtailing rumors through the dissemination of coordinated, accurate information. Responds to the accident/incident site, to the Command Post and to the Public Affairs duty section where an information center may be established.

3.2.7.3 The presence of hazardous waste in a contained area will probably not constitute reasonable cause to forcibly deny access to the area by accredited news media representatives. Applicable security and safety provisions will apply; however, under no circumstances will Public Affairs office personnel escort news media representatives into a hazardous or potentially dangerous area.

3.2.8 Requirements for Commanders of Units That Generate Hazardous Waste

3.2.8.1 Complies with requirements of this HWMP to include providing continuing support for the safe management of hazardous wastes.

3.2.8.2 Submits requests to CEIE to ensure all wastes are evaluated and that hazardous wastes are properly classified.

3.2.8.3 Provides safe equipment and locations for satellite accumulation points or accumulation sites.

Coordinates each location with CEIE, Ground Safety, Fire Department, and BEs.

3.2.8.4 Ensures the management of hazardous waste accumulation and/or generation sites complies with federal and state hazardous waste management regulations.

3.2.8.5 Appoints HW managers and an alternate for activities that generate hazardous waste as the hazardous waste Satellite Accumulation Point Manager (SAPM).

3.2.8.5.1 The appointment will be in writing by an organization commander.

3.2.8.5.2 CEIE will be notified of any changes regarding the appointed manager.

3.2.8.5.3 This manager will retain overall responsibility for the management of the accumulation site.

For military supervisors, management duties may be delegated by the shop supervisor, but to no lower that an E-5 (Staff Sergeant). Waivers to this requirement may be submitted to CEIE if hazardous waste generating shops cannot comply because of personnel and/or rank limitations. Forward a letter of designation to CEIE for updating the accumulation point records.

3.2.8.6 Budgets for storage and emergency spill response of HW.

3.2.8.7 Ensures SAPM can and does perform his/her duties in accordance with this plan.

3.2.8.8 Allows appropriate facilities, shops and equipment to be inspected for hazardous waste management regulatory compliance by CEIE and authorized State or Federal inspectors.

3.2.8.9 Ensures that all personnel handling hazardous waste, or who are otherwise involved in hazardous waste management, receive required training.

3.2.8.10 Ensures each generating activity properly completes all required documentation (hazardous waste profile sheet, turn in documents).

3.2.9 Hazardous Waste Accumulation Point Managers and Alternates

The managers assume overall responsibility for management of the non-hazardous and hazardous waste accumulation points. All generators of hazardous and non-hazardous waste must be capable of recognizing, tracking and maintaining all documentation necessary for proper hazardous waste management. Refer to Appendix D for Accumulation and Generation Points.

Note: Satellite Accumulation Point Managers and alternates will be appointed in writing.

3.2.9.1 Ensures safety equipment is used to handle each waste.

3.2.9.2 Maintains copies of Material Safety Sheets for each component of the waste.

3.2.9.3 Ensures emergency numbers are posted by the phone.

3.2.9.4 Ensures all individuals in the activity that generate, handle, store, or have the potential to be exposed to hazardous and non-hazardous waste are trained. Documents the training.

3.2.9.5 Coordinates with CEIE, Fire Department, BE, and Ground Safety on relocation of accumulation site.

3.2.9.6 Ensures accumulation site has appropriate warning signs (i.e., “No Smoking”).

3.2.9.7 Ensures the accumulation site has a spill kit, when needed.

3.2.9.8 Ensures an approved fire extinguisher is readily available if flammable hazardous waste is stored in the accumulation site.

3.2.9.9 Performs and documents weekly inspections of the accumulation site and initiates remedial actions in the event of leaks, spills, or improper storage. Inspections must be performed weekly for containers and daily for tanks. Maintains a notebook of inspection reports.

3.2.9.10 Ensures all hazardous and non-hazardous wastes are stored, handled, packaged, and labeled properly.

3.2.9.11 Ensures hazardous wastes are in appropriate (authorized) containers capable of being loaded and transported. A representative of the generating activity must accompany the vehicle operator to the Hazardous Waste Central Accumulation Site, Building 685.

3.2.9.12 Maintains hazardous waste containers in proper condition, e.g., no pitting, no sharp edge creases or dents, no material defects, no bulging heads or rust.

3.2.9.13 Ensures all waste containers will be placed in secondary containment.

3.2.9.14 Ensures all containers will be handled by trained personnel using gloves and protective clothing, as required by the Material Safety Sheet and the manufacturer‟s label.

3.2.9.15 Ensures containers are clean with no residue on the container.

3.2.9.16 Ensures all waste containers must be labeled with the appropriate label PRIOR to placing waste in the container. There must never be a doubt about the contents of a container holding hazardous waste.

3.2.9.17 Ensures containers are kept closed except when they are being filled.

3.2.9.18 Ensures all hazardous waste is placed in an approved accumulation site.

3.2.9.19 Maintains an accumulation site container log. Will account for all drums at an accumulation site. Peterson AFB accumulation site managers will maintain an accumulation site container log if requested by HWMP.

3.2.9.20 When a hazardous waste spill is detected, stops all other actions and, if safe to do so, contains spill to best of ability based on unit capability and resources. Notify the base Fire Department (ext. 911).

3.2.9.21 Maintains all hazardous waste documentation and correspondence for a minimum of 3 years.

3.2.9.22 Ensures all waste is transported safely using Government owned vehicles.

3.2.10 Staff Judge Advocate (21 SW/JA)

3.2.10.1 Reviews federal, state and local hazardous waste management regulations. Advises the ESOHC and the installation commander on how these regulations apply to installation host and tenant activities.

3.2.10.2 Provides legal advice in the development of the hazardous waste management plan.

3.2.10.3 Reviews all regulatory agency correspondence and verbal requests.

3.2.10.4 Reviews all fee and permit assessments.

3.2.10.5 Advises commanders of liabilities associated with failing to comply with environmental laws and regulations.

3.2.10.6 Provides staff support and serves as the legal advisor to the installation commander in negotiating memorandums of understanding and compliance agreements.

3.2.10.7 Serves as legal counsel in negotiating compliance agreements in response to Notices of Violations or other enforcement action.

3.2.11 Safety (21 SW/SE)

3.2.11.1 Coordinates on and approves citing locations of accumulation points.

3.2.11.2 Includes hazardous waste accumulation sites during the annual ground safety inspection. Safety deficiencies will be made a part of the formal inspection report.

3.2.12 Base Environmental Safety Occupational Health Committee (ESOHC)

3.2.12.1 Reviews and assists in implementation of the Hazardous Waste Management Program.

Establishes policies and procedures that are necessary to safely manage HW.

3.2.12.2 Reviews regulatory agency correspondence, especially inspection reports and notices of noncompliance.

3.2.12.3 Conducts annual review of the Hazardous Waste Management Plan.

3.2.13 Base Fire Department (21 CES/CEF)

3.2.13.1 Inspects and approves the location of hazardous waste accumulation points.

3.2.13.2 Provides emergency response and spill containment for all hazardous waste spills, when notified.

4.0 Hazardous Waste Stream Inventory and Locations

4.1 Hazardous Waste Locations

4.1.1 The Hazardous Waste Accumulation Map located at Appendix E, shows buildings at PAFB where satellite accumulation points are located and Building 685 where hazardous wastes may be stored (central accumulation site) for up to 180 days prior to disposal after being moved from generation points or…