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BY ORDER OF THE COMMANDER
EGLIN AIR FORCE BASE
EGLIN AIR FORCE BASE INSTRUCTION
32-7003
22 APRIL 2015
Civil Engineering
HAZARDOUS WASTE MANAGEMENT
COMPLIANCE WITH THIS INSTRUCTION IS MANDATORY
ACCESSIBILITY: Publications and forms are available on the e-publishing website at www.e-Publishing.af.mil for downloading or ordering
RELEASABILITY: There are no releasability restrictions on this publication
OPR: 96 CEG/CEIEC
Supersedes: EGLINAFBI32-7003, 1 November 2010
Certified by: 96 CEG/CC
(Col Moore)
Pages: 52
This instruction implements AFPD 32-70, Environmental Quality and AFI 32-7042, Solid and
Hazardous Waste Compliance. The AFI and this instruction identify compliance requirements for all hazardous waste, Universal Waste, certain Special Waste and used petroleum products. It does not cover radioactive waste. This instruction applies to all organizations (host, associates, activities, contractors, and personnel, but not residential households), which generate hazardous waste at Eglin Air Force Base. Refer recommended changes and questions about this publication to the Office of Primary Responsibility (OPR) using the AF Form 847, Recommendation for
Change of Publication; route AF Form 847s from the field through the appropriate functional’s chain of command. Ensure that all records created as a result of processes prescribed in this publication are maintained IAW Air Force Manual (AFMAN) 33-363, Management of Records, and disposed of IAW Air Force Records Information Management System (AFRIMS) Records
Disposition Schedule (RDS).
SUMMARY OF CHANGES
This document has been minimally revised but should be reviewed completely. Revisions include:
replacement of HMMS with the new tracking/disposal system EESOH-MIS, removal of
Environmental Compliance’s PPBE responsibilities, replacement of the term used POL with used oil, removal of annual waste profile update requirement, changes in training sources, addition of http://www.e-publishing.af.mil/
2 EGLINAFBI32-7003 22 APRIL 2015
Recycle Center to accept generator’s lead acid/NiCd batteries, change the term issue points to
Hazmarts, removal of non-accumulation sites, and administrative changes.
Chapter 1—PROGRAM OVERVIEW 6
1.1. Concept
Chapter 2—GENERAL REQUIREMENTS 7
2.1. Management and Control
2.2. Environmental Management System (EMS) Goals, Objectives and Targets
2.3. Basic Structure and Outline
Chapter 3—RESPONSIBILITIES 9
3.1. Commander, (96 TW/CC)
3.2. Environmental Management Function (96 CEG/CEIEC)
3.3. Unit Commanders, Equivalents and Subordinate Managers (Generating
Activities, Associates and Contractors)
3.4. Staff Judge Advocate (96TW/JAV)
3.5. Waste Disposal Contractor
3.6. Financial Management (96 CEG/CEIAR)
3.7. Unit Environmental Coordinators (UECs)
3.8. Public Affairs (96 TW/PA)
3.9. ACCS, IAP, UW, SPW, and used oil Managers and Alternates
Chapter 4—TRAINING 14
4.1. Basic Resource Conservation and Recovery Act (RCRA) Requirement
4.2. HW Training System
4.3. Other Related Training
4.4. Training Records
Chapter 5—WASTE DETERMINATION, ANALYSIS PLAN AND INVENTORY
REQUIREMENTS 16
5.1. Basic HW Determination/Identification
5.2. Waste Analysis
Table 5.1. Recommended Waste Laboratory Analysis Reevaluation Frequencies
5.3. Waste Stream Description/Profile
Table 5.2. Profile and Accumulation Site Numbering System
5.4. Hazardous Waste Inventory
EGLINAFBI32-7003 22 APRIL 2015 3
5.5. Abandoned Waste
Chapter 6—HAZARDOUS WASTE ACCUMULATION SITE OPERATIONS 19
6.1. Container Tracking System
6.2. Types of Storage Areas
6.3. Accumulation Container Management
Figure 6.1. Hazardous Waste Label
6.4. Operating Procedures
Table 6.1. IAP and ACCS Postings and Records
6.5. Turn-In Requirements and Procedures
Table 6.2. Waste Not Accepted by DRMO
6.6. Disposal of Expired, Unneeded or Unserviceable Hazardous Material Products. . 24
Chapter 7—MANAGEMENT OF UNIVERSAL WASTE, SPECIAL WASTE, USED
PETROLEUM PRODUCTS (POL) AND OTHER SPECIFIC WASTES 27
7.1. Special Wastes General
7.2. Universal Waste General
7.3. Universal Waste Mercury Lamps and Universal Waste Mercury Devices
7.4. Waste Batteries
Table 7.1. SPW Batteries. From Department of the Army Technical Bulletin 43-0134
Table 7.2. UW Batteries Historically Generated at Eglin AFB
7.5. Special Instructions for UW Lithium-Sulfur Batteries
7.6. Aerosol Cans
7.7. Solder
7.8. Rags and Wipers
7.9. Used Filters
7.10. Compressed Gas Cylinders
7.11. Free Liquid Clarification
7.12. Blast Media
7.13. Refrigerant Oils
7.14. Polychlorinated Biphenyls (PCBs)
Figure 7.1. PCB Caution labels (choose one)
Figure 7.2. DOT Hazard Class label
7.15. Used oil Products
7.16. Petroleum Contact Water
4 EGLINAFBI32-7003 22 APRIL 2015
Chapter 8—WASTE MILITARY MUNITIONS 37
8.1. Military Munitions (MM)
8.2. Military Munitions Waste Determination
8.3. Military Munitions Classification
8.4. Military Munitions Treatment and Disposal
Chapter 9—MANIFESTING AND LAND DISPOSAL RESTRICTION REQUIREMENTS
9.1. HW Manifest and Restricted Waste Notification Form
Chapter 10—CLOSURE/POST CLOSURE PLAN 40
10.1. The Defense Reutilization and Marketing Office Permitted Storage Facility
10.2. Explosive Ordnance Disposal (EOD) Storage and Treatment Facility closure
10.3. IAP and 45-Day ACCS Closures
Chapter 11—EMERGENCY PLANNING/RESPONSE REQUIREMENTS 41
11.1. Personnel Safety
11.2. Emergency Planning
Figure 11.1. Sample HW Accumulation Site Spill Plan
11.3. Emergency Preparedness
Figure 11.2. Emergency
11.4. Emergency Spill Response Actions
Chapter 12—POLLUTION PREVENTION/WASTE MINIMIZATION 45
12.1. Pollution Prevention Overview
12.2. Source Reduction
12.3. Reclaim/ Reuse
12.4. Treatment
12.5. Disposal
12.6. Pollution Prevention Program
12.7. Excess Material Redistribution and Control
Chapter 13—PUBLIC AFFAIRS PLANNING 47
13.1. Environmental Public Affairs Overview
13.2. Hazardous Waste Media Queries
Attachment 1—GLOSSARY OF REFERENCES AND SUPPORTING INFORMATION 48
EGLINAFBI32-7003 22 APRIL 2015 5
Attachment 2—CHECKLIST TO SET UP OR CHANGE A WASTE COLLECTION SITE
6 EGLINAFBI32-7003 22 APRIL 2015
Chapter 1
PROGRAM OVERVIEW
1.1. Concept. This instruction provides a framework for complying with environmental standards applicable to Hazardous Waste (HW), Universal Waste (UW), Special Wastes (SPW), and used petroleum, oil, and lubricants (POL) at Eglin Air Force Base (AFB). It is designed to provide the Installation Commander the appropriate level of confidence that Eglin AFB is operating in accordance with the requirements of the applicable HW regulations. Use the procedures in this instruction to comply with applicable Federal, State, and local standards for
HW, UW, SPW and used oil management.
1.1.1. This instruction establishes a hazardous waste plan and provides policies and procedures for the management of HW at Eglin AFB. It applies to all organizations (host, associates, activities, contractors and personnel, but not residential households) that generate
HW, UW, SPW and used oil within the jurisdiction of Eglin AFB. It is designed to identify alternatives to disposing of HW by reducing or eliminating the volume of waste generated.
1.1.2. Environmental Compliance (96 CEG/CEIEC) provides technical assistance to all base activities regarding proper management of HW, UW, SPW and used oil to ensure compliance with federal, state, local regulations, and Air Force instructions. 96 CEG/CEIEC is the single point of contact to the Florida Department of Environmental Protection (FDEP) for all issues regarding HW, UW, SPW and used oil on Eglin AFB.
1.1.3. Any deficiencies or inaccuracies noted in this instruction or difficulties complying with this instruction or any HW law or regulation must be reported to 96 CEG/CEIEC.
EGLINAFBI32-7003 22 APRIL 2015 7
Chapter 2
GENERAL REQUIREMENTS
2.1. Management and Control. This instruction provides Eglin AFB with a hazardous waste management plan which addresses the mandatory HW management requirements of the
Environmental Protection Agency (EPA), Florida Department of Environmental Protection
(FDEP) and United States Air Force (USAF). It covers the control and management of Hazardous
Materials (HM) from the point they become waste to the point of final disposition. This instruction does not cover radioactive or medical wastes, which are regulated under separate guidance.
2.1.1. The installation commander (96 TW/CC), through subordinate commanders, is responsible for installation compliance with HW management and disposal laws and regulations. Disposal of HW by the waste disposal contractor or Defense Reutilization and
Marketing Office (DRMO) does not relieve the installation commander of this obligation.
2.1.2. The requirements addressed apply to all organizations located on Eglin AFB including associates, contractors and units here temporarily. 96 CEG/CEIEC provides for HW disposal through the DRMO. Contracting for the disposal or off site transfer of HW without the coordination of 96 CEG/CEIEC is prohibited.
2.1.3. Organizations appoint Unit Environmental Coordinators (UEC), Initial Accumulation
Point (IAP), 45-Day Accumulation Site (ACCS), Universal Waste (UW) collection site, Special Waste (SPW) collection site, and used oil accumulation site managers and alternates.
A copy of each UEC appointment memorandum shall be submitted to 96 CEG/CEIEC. A listing of waste collection site managers and alternates will be maintained in the Enterprise
Environmental, Safety and Occupational Health Management Information System (EESOH-
MIS). Organizations will coordinate with 96 CEG/CEIEC as required to maintain accurate information in EESOH-MIS.
2.2. Environmental Management System (EMS) Goals, Objectives and Targets. The hazardous waste program may be assigned goals, objectives, and targets which must be measured and reported.
2.3. Basic Structure and Outline. The following outlines the structure of the plan and incorporates the referenced sections of this instruction.
2.3.1. Responsibilities. Chapter 3 incorporates the responsibilities of all Eglin military, civilian and contractors operating at Eglin AFB FL.
2.3.2. Training. Chapter 4 includes HW and other related training requirements and instructions.
2.3.3. Waste Determination, Analysis, and Inventory. Chapter 5 includes procedures to ensure that waste constituents (listed or characteristic) are adequately identified; to develop and maintain a HW inventory describing waste types and quantities, associated EPA waste code(s), and waste profile number(s); and to adequately document HW description of each unique waste stream. The Defense Reutilization and Marketing Service (DRMS) Form 1930 or EESOH-
MIS equivalent, Hazardous Waste Profile Sheet is the record document.
2.3.4. Accumulation Site Operations. Chapters 6, 7 and 8 include procedures to ensure proper management of containers and accumulation sites; to adequately document waste turn-in and
8 EGLINAFBI32-7003 22 APRIL 2015
to ensure timely disposition of wastes; to ensure that appropriate monitoring and record keeping is accomplished for all accumulation sites; to ensure the proper management and disposition of abandoned waste, UW, other controlled non-HW, and waste military munitions
(WMM).
2.3.5. Manifesting and Land Disposal Restriction Requirements. Chapter 9 outlines the requirements for completion, tracking, and recordkeeping associated with these documents.
Only those individuals appointed by the installation commander have signature authority.
2.3.6. Closure/Post Closure Plan. Chapter 10 identifies the requirements for closure of permitted and non-permitted HW facilities.
2.3.7. Emergency Response/Planning Requirements. Chapter 11 of this instruction provides basic site-specific emergency response and planning guidance for all HW generators and their respective accumulation points.
2.3.8. Pollution Prevention/Waste Minimization. Chapter 12 outlines the Pollution Prevention
(P2) requirements based on Eglin’s Resource Conservation and Recovery Act (RCRA) Part B
Subpart X permit and Eglin’s status as a Large Quantity Generator (LQG).
2.3.9. Public Affairs Planning. Chapter 13 identifies the role Public Affairs has in planning for HW emergencies and the requirements for addressing the public and media during and/or subsequent to emergency situations.
EGLINAFBI32-7003 22 APRIL 2015 9
Chapter 3
RESPONSIBILITIES
3.1. Commander, (96 TW/CC). Responsible official for overall compliance with HW, UW, SPW and used oil requirements. Assigns responsibility for management of Eglin’s HW Program to 96 CEG/CEIEC. Ensures development and publication of this instruction. Oversees the implementation of this instruction.
3.2. Environmental Management Function (96 CEG/CEIEC).
3.2.1. Serves as the focal point for all environmental matters. Serves as the overall HW
Program Manager (HWPM) and provides policies and procedures to the Eglin AFB installation community. Policy and procedures are provided through this instruction, eDASH and the environmental management web pages to include the environmental document control system, the unit environmental coordinator information center, and the hazardous waste web page.
Provides advice and consultation on all environmental laws, regulations, and policies.
Establishes the appropriate course of action to resolve discrepancies. Acts as the interface for all base organizations with federal, state, and local regulatory agencies.
3.2.2. Acts as the Office of Primary Responsibility (OPR) to develop, manage, coordinate and forward instruction updates to Base Publications (96 CS/SCOK) for publication and distribution.
3.2.3. 96 CEG/CEIEC serves as the EMS operator for HW Program Goals, Objectives, and
Targets and is responsible for any required monthly EMS updates and managing assigned EMS goals, objectives, and targets.
3.2.4. Serves as Secretary of the Environment, Safety, and Occupational Health Council
(ESOHC) and implements direction of the HW program from the ESOHC.
3.2.5. Develops/updates RCRA Part B Subpart X [(Miscellaneous Units, Open Burn Open
Detonation)] Permit and negotiates special conditions with FDEP. Provides technical environmental support and ensures special conditions of the permit are complied with. This includes groundwater monitoring and reporting and preparation and submission of the EPA
Biennial Report.
3.2.6. Requires each generating organization (of HW, UW, SPW, used oil) to appoint a primary and alternate UEC who serve as a member of the UEC Council. Maintains a current roster of appointed UECs (primary and alternates).
3.2.7. Develops a comprehensive HW self-inspection/auditing program for Eglin AFB activities. Performs HW accumulation point monitoring and auditing as required.
3.2.8. Includes all applicable base organizations in internal/external Environmental, Safety, and Occupational Health Compliance Assessment and Management Program (ESOHCAMP) evaluations. Forwards HW deficiencies to and coordinates appropriate remedies with the responsible organizations.
3.2.9. Provides all base HW generating organizations with appropriate training on HW management, environmental compliance, and other appropriate environmental topics.
3.2.10. Provides HW disposal capability as outlined in this instruction.
10 EGLINAFBI32-7003 22 APRIL 2015
3.2.11. Provides oversight of HW emergency cleanup operations within the boundaries of the installation. These services will be provided under the Spill Prevention Control and
Countermeasures (SPCC) Plan, the Weekly Bayou Marine Fuel Transfer Facility Plan, and the installation Full Spectrum Threat Response Plan.
3.2.12. Notifies the responsible organization(s) as soon as a potential Notice of Violation
(NOV) is identified and coordinates remedies with the respective organization(s).
3.2.13. Develops, implements, and maintains a complete and current HW stream inventory and container tracking system to monitor and control HW containers at all accumulation sites.
3.2.14. Approves all ACCS, IAP, UW, SPW, and used oil sites on Eglin property. Maintains a current record of ACCS, IAP, UW, SPW, and used oil accumulation point managers/alternates and their respective accumulation points.
3.2.15. Facilitates proper characterization of all waste streams in accordance with RCRA requirements and pertinent information provided by the generating organization. Facilitates appropriate waste stream sampling and analysis with the waste disposal contractor. Provides technical oversight and Quality Assurance of contractor sampling, analysis and Quality
Control activities. Facilitates waste profile creation including sampling and analysis as required by this instruction.
3.3. Unit Commanders, Equivalents and Subordinate Managers (Generating Activities, Associates and Contractors).
3.3.1. Implement EMS goals, objectives, and targets with guidance and technical assistance of the UEC and the 96 CEG/CEIEC team.
3.3.2. Ensure that personnel involved in the management of HW are properly trained, as applicable, to their level of HW management duties.
3.3.3. Identify the employee(s) to be trained, their duties and responsibilities, and their required level of training.
3.3.4. Develop an individual training plan (ITP) for key personnel in HW management based on the individual’s assigned duties and responsibilities. Ensures training records are maintained in the personnel training folder or appropriate data system. Training documentation must be readily available for review by inspectors. Maintains records indefinitely for employees handling wastes. Maintain records for 3 years after an employee no longer handles wastes.
3.3.5. Ensure shop specific training including Eglin EMS Awareness Training, HW Training, and Hazard Communication is provided to and is completed by employees as required by this instruction.
3.3.6. Strive to minimize HW generation through oversight of organizations’ operations by means of material substitution, source reduction, recycling/reuse, or elimination of waste generation.
3.3.7. Ensure that all operations under their command maintain compliance with all HW laws and regulations.
3.3.8. Designate in writing to 96 CEG/CEIEC by the organization commander or equivalent a primary and alternate member to serve on the UEC Council. Assures that the designees’ job
EGLINAFBI32-7003 22 APRIL 2015 11
descriptions and periodic evaluations reflect environmental duties and these duties are included in the evaluation criteria. Contractors are required to maintain programs to ensure their respective company complies with the requirements of this instruction. In addition, the contractor will assist the respective government UEC concerning environmental matters related to the government organization contracting their services.
3.3.9. Ensure a primary and alternate member are assigned to manage and maintain individual
ACCSs, IAPs, SPW, UW, and accumulation of used oil. Contractor operated waste accumulation sites and used oil accumulation containers are also required to have managers and alternates assigned.
3.3.10. Determine need for organization’s HW manifest signature authority. Nominate, in writing to 96 CEG/CEIE, personnel requiring HW manifest signature authority.
3.3.11. Serve as the primary member of the ESOHC for their organization(s).
3.3.12. Provide process information to the UEC and 96 CEG/CEIEC for proper characterization of any waste generated whenever a change in the process producing the waste stream occurs. Technical information is necessary to properly characterize all shop waste streams. Changes in the waste stream are likely when the processes, process chemicals, chemical concentrations, and/or manufacturers change.
3.3.13. Coordinate with the UEC, 96 CEG/CEIEC and/or waste disposal contractor to determine characterization, segregation, packaging, marking, labeling, pre-disposal and storage requirements, and procedures for wastes generated.
3.3.14. Notify the UEC when waste accumulation site changes occur.
3.3.15. Assure that all ACCS, IAP, UW, SPW, and used oil site managers and alternates are assigned by the shop supervisor with concurrence of the UEC.
3.3.16. Ensure that all waste accumulation/storage sites no longer necessary within their organization are closed and comply with the guidelines in this instruction for HW facility closures.
3.4. Staff Judge Advocate (96TW/JAV).
3.4.1. Reviews all permit applications for legal sufficiency.
3.4.2. Provides legal advice and representation for any and all matters related to HW, UW, SPW and used oil compliance, as necessary.
3.5. Waste Disposal Contractor.
3.5.1. Accepts, collects, and processes turn-in documentation for wastes and excess hazardous materials from all of Eglin’s organizations regardless of the physical location. Movement of wastes to the DLA Disposition Services ACCS must be accomplished within one work day for customers within the base boundary, and two work days for customers located off of the base boundary.
3.5.2. Collects samples of HW, potential HW, or SPW, base-wide as directed by 96
CEG/CEIEC. Samples and sampling methods will comply with methods specified in the AFI
32-7042, Solid and Hazardous Waste Compliance. Forward copies of analytical data to 96
12 EGLINAFBI32-7003 22 APRIL 2015
CEG/CEIEC. Retains results of the data obtained from the analysis of the samples for five years.
3.5.3. Provides copies of all 1348-1a documents, profile sheets, and sample analyses to generators. Supplies containers and labeling for waste accumulation.
3.6. Financial Management (96 CEG/CEIAR).
3.6.1. Will collect expense data associated with hazardous waste and non-hazardous waste collection, handling, and disposal.
3.7. Unit Environmental Coordinators (UECs).
3.7.1. Monitor overall organizational environmental compliance and serve as an advisor to their organization on environmental issues.
3.7.2. The following applies to UECs representing organizations which generate/manage HW, UW, SPW, and used oil.
3.7.2.1. Serve as the HW operations liaison between Environmental Program managers/contractors and the unit to address issues related to maintaining environmental compliance with the HW laws, regulations and Air Force requirements. This includes management and disposition of abandoned wastes.
3.7.2.2. Assist the HW Program Manager in the management of assigned EMS goals, objectives, and targets.
3.7.2.3. Ensure compliance with the following for shops and activities that generate HW, UW, SPW, and used oil.
3.7.2.3.1. Identify wastes generated and provide updates on waste streams as necessary, to 96 CEG/CEIEC. It is the responsibility of the UEC to request waste profile changes from 96 CEG/CEIEC.
3.7.2.3.2. Maintain a current listing of the types and locations of HW, UW, and SPW generation, storage, and the method of disposal.
3.7.2.4. Ensure information pertaining to respective waste collection sites [e.g., DRMS
Form 1930 HW Profile Sheets or EESOH-MIS equivalent, inspection logs, spill reports, this instruction, and training documentation] is readily available.
3.7.2.5. Ensure ACCSs, IAPs, UW sites, SPW sites, and used oil accumulation sites are in compliance with applicable regulations, including this instruction, through documented biannual inspections and audits of generating activities. Concur with the assignment of
ACCS, IAP, UW, SPW, and used oil managers and/or alternates and ensure assignment information is accurately maintained in EESOH-MIS. Recommends or concurs on the establishment or closure of ACCS, IAP, UW sites, SPW sites, or used oil sites. Ensure all
ACCS, IAP, UW, SPW, and used oil site information is provided to environmental management for approval and tracking.
3.7.2.6. Provide inventory of hazardous waste streams and respective collection site information to 96 CEG/CEIEC. Inventory information will be provided or updated as new or potential waste streams are identified or changes to existing waste streams occur.
EGLINAFBI32-7003 22 APRIL 2015 13
3.7.2.7. Coordinate data (inventory) collection, assess unit environmental conditions and requirements when a hurricane condition or exercise occurs. After assessment, contact 96
CEG/CEIEC and/or the waste disposal services contractor for assistance in moving/securing HW containers if needed. After an actual hurricane, UECs will check previous data (inventory) and determine if all HW containers are accounted for and in good condition. Report any releases/spills or other problems to the unit commander and 96
CEG/CEIEC.
3.7.2.8. In coordination with shop supervisors determine all personnel in their organization who require either Accumulation Point Management or HW Awareness training and ensure that this training is received, documented, and updated at required intervals.
3.7.2.9. Ensure shop specific training (e.g., ACCS/IAP/UW/SPW/POL Training) is provided, as necessary, to fulfill the training requirements for HW, UW, SPW and used oil management as specified in this instruction.
3.8. Public Affairs (96 TW/PA).
3.8.1. Provides public announcements and coordinates public inquiries associated with HW and/or emergency response activities.
3.9. ACCS, IAP, UW, SPW, and used oil Managers and Alternates.
3.9.1. Manage ACCS, IAP, UW, SPW, and used oil accumulation IAW the requirements of this instruction.
3.9.2. Report all ACCS, IAP, UW, SPW, and used oil generation to the organization’s UEC and 96 CEG/CEIEC for waste characterization and waste collection site management.
3.9.3. Ensure the potential generation of new waste streams is identified and reported to the
UEC and 96 CEG/CEIEC prior to generation.
3.9.4. Assure current signed HW Profile Sheets (DRMS Form 1930) or EESOH-MIS equivalent are available for each respective waste collection site. If waste does not have current signed profile, contact the UEC for assistance.
3.9.5. Complete required annual HW training. For those individuals authorized by 96
CEG/CEIEC to sign manifests, complete Department of Transportation (DOT) training every two years.
14 EGLINAFBI32-7003 22 APRIL 2015
Chapter 4
TRAINING
4.1. Basic Resource Conservation and Recovery Act (RCRA) Requirement. If you handle or have occupational exposure to HW, you are required by RCRA to receive training on the proper management of HW and response to any emergency. It is Air Force policy that all personnel who handle HW and their supervisors must successfully complete HW training before handling HW.
They must also successfully complete annual refresher training. Training must be documented by the organization and training records must be kept for three years after the employee departs.
4.2. HW Training System.
4.2.1. Training sources include the College of Installation Sustainment and Management, the
96 CEG/CEIEC Environmental Management Information Training Portal, the Education and
Training Flight (96 FSS/FSDE), Air Force Civil Engineering Center (AFCEC) Environmental, Safety, and Occupational Health Training Network, Air Force Institute of Technology (AFIT courses or funding for commercial sources), the organization (fund/arrange for government or commercial courses), or the organization’s UEC (awareness, ACCS, IAP, UW, SPW, and used oil).
4.2.2. HW classroom training is provided by 96 CEG/CEIEC through the Education and
Training Flight (96 FSS/FSDE). Personnel taking hazardous waste training at Eglin for the first time are encouraged to take this classroom training.
4.2.3. Web-based training is available for personnel requiring annual refresher training or awareness training. This training can be found on the Environmental Management Information
Training Portal.
4.2.4. HW Awareness Training is required for all personnel and their supervisors who may be reasonably expected to encounter HW in their work area even if they do not handle HW.
Refresher awareness training is required annually.
4.2.5. General HW Training is required for all personnel and their supervisors who handle
HW. Personnel that manage an ACCS, IAP, UW, SPW, and/or used oil site (and their supervisors) must take General HW training and Eglin specific ACCS/IAP/UW/SPW/used oil collection site training. The UEC for organizations that generate hazardous waste must take
General HW training and Eglin specific training for all types of waste collection sites within their organization. The UEC for organizations that do not generate hazardous waste must take
HW Awareness training. Refresher training is required annually.
4.2.6. Personnel who characterize hazardous wastes, provide HW management training, or make HW management program decisions are required to complete General HW training and
Eglin specific ACCS/IAP/UW/SPW/used oil waste collection site training. These personnel are also required to annually complete more in-depth formal hazardous waste management courses/seminars/workshops available through off site government or commercial providers.
This annual training is expected to be 16 to 40 hours of course work.
4.2.7. Personnel who participate in the preparation, transportation, and/or treatment of waste military munitions at the permitted open burn open detonation sites require annual waste military munitions training. Training may be provided through the organizational unit, Eglin
EGLINAFBI32-7003 22 APRIL 2015 15
specific web based waste military munitions training, or 96 CEG/CEIEC. This training may be supplemented with Defense Transportation Regulation specified training.
4.2.8. All personnel are required to complete the Eglin EMS Awareness training. Training may be provided through the organizational unit, 96 CEG/CEIE website, or 96 CEG/CEIEC.
4.3. Other Related Training.
4.3.1. Department of Transportation (DOT) HAZMAT Training. Personnel designated to sign manifests, transport DOT hazardous materials (HM) over public roads or otherwise direct shipment of any DOT HM (including HW), and their supervisors are required by DOT regulations to receive training on proper shipping management. Training must be completed in accordance with Defense Transportation Regulation requirements prior to performing or supervising these activities. Refresher training is required every 2 years.
4.3.2. Hazardous Waste Operations and Emergency Response Training (HAZWOPER).
Individuals assigned to Explosive Ordnance Disposal (EOD) who direct, participate in or conduct follow-up activities related to the RCRA Treatment, Storage, and Disposal Facility
(TSDF) Part B Subpart X permitted treatment/disposal of waste military munitions must complete HAZWOPER training or equivalent training, in addition to the required waste military munitions training and DOT training. Initial HAZWOPER training is a 40 hour course and annual refresher training is 8 hours.
4.3.3. Instructor and Other Personnel Requiring the Highest Level of Proficiency. 96
CEG/CEIEC requires all individuals (generally UECs and 96 CEG/CEIEC personnel), who provide supplemental site or other HW training (above the awareness level), to annually complete a 16 hour (minimum) off-site provided RCRA HW course. In addition, a train the trainer course is recommended for instructors.
4.4. Training Records. Training must be documented in the individual’s training records.
Organizations are responsible for ensuring training documentation is maintained for all employees until three years after the employee departs. A copy of all HW training records must be readily available for inspection.
16 EGLINAFBI32-7003 22 APRIL 2015
Chapter 5
WASTE DETERMINATION, ANALYSIS PLAN AND INVENTORY REQUIREMENTS
5.1. Basic HW Determination/Identification. Any solid, liquid, semi-solid, or contained gaseous material, which is discarded or abandoned, must be evaluated to determine if it is a HW and subject to regulation under RCRA.
5.1.1. A waste is subject to regulation as a hazardous waste if it is not excluded from regulation and it exhibits any of the hazardous characteristics specified in 40 CFR 261 Subpart C
(Ignitability, Corrosivity, Reactivity, or Toxicity) or if it is listed in 40 CFR 261 Subpart D.
5.1.2. Determination Responsibility. All organizations that generate and/or store potential HW are responsible for determining the hazardous characteristics of the waste generated and/or stored and the applicability of RCRA requirements. The HW disposal services contractor (882-
7664) or 96 CEG/CEIEC (882-7667), and the DRMO (882-8076) will provide technical assistance.
5.2. Waste Analysis. This describes the method by which wastes are characterized. This information will allow 96 CEG/CEIEC, DRMO and/or the HW disposal services contractor to utilize standard references in order to verify and/or determine the chemical characteristics, proper storage requirements, Land Disposal Restrictions and DOT shipping requirements for HW, and to complete the HW profile (DRMS Form 1930 or EESOH-MIS equivalent), Issue Release/Receipt
Document (DD Form 1348-1A), and/or the HW Manifest and the Land Disposal Restriction (LDR) form. Waste characterization may be conducted by any combination of the following:
5.2.1. Determination of the waste constituents by referring to specific waste stream turn-in documents and waste profile sheets.
5.2.2. Determination of waste constituents through the use of Safety Data Sheets (SDSs), original manufacturer’s labels and/or and user knowledge of process contaminants and by-products generated. The generator should contact the manufacturer if an SDS is not available.
5.2.2.1. Identification of the noun name and national stock number (NSN) as catalogued in the Federal Supply System, if applicable.
5.2.2.2. Identification of the chemical names of hazardous contaminants and noun name of non-hazardous contaminants.
5.2.2.3. Amounts of hazardous and non-hazardous contaminants expressed in range of content by percentage on parts per million, as available and applicable.
5.2.3. Use of reference materials, including those available through a variety of internet web sites.
5.2.4. Laboratory analysis of the potentially characteristic waste generated utilizing methods described in 40 CFR 261.10. Wastes requiring analysis are recommended to be reevaluated according to the frequencies specified in Table 5.1.
5.2.4.1. If an analysis for an unknown or existing waste stream is required, the HW generating organization will submit a written request for sampling and analysis of the waste stream to 96 CEG/CEIEC. The generator will activate this process as early as possible to avoid exceeding the storage time limit.
EGLINAFBI32-7003 22 APRIL 2015 17
5.2.4.2. 96 CEG/CEIEC will furnish a written request for sampling and analysis to the waste disposal contractor, track the sampling effort, return analysis documentation to the generating organization, and prepare the HW profile sheet for generator signature.
5.2.5. The generating site’s supervisor/manager or UEC is responsible for notifying 96
CEG/CEIEC of new waste streams or any changes to current waste generating processes.
Notification must include the process identification, waste stream profile number (if applicable), waste collection site number (if applicable), current container control number (if applicable), site manager name and phone number, and a description of change(s) occurring to existing HW streams. Generators will provide all information required by Attachment 2 to 96
CEG/CEIEC or the HW disposal services contractor through their UEC.
Table 5.1. Recommended Waste Laboratory Analysis Reevaluation Frequencies
HW Stream Annual Volume Frequency
More than three 55 gallon drums Annual
Three 55 gallon drums or less Every 3 years
All HW Whenever process changes
5.3. Waste Stream Description/Profile. Waste stream descriptions and respective Hazardous
Waste Profile Sheets (DRMS Form 1930 or EESOH-MIS equivalent) will be updated whenever the process changes or laboratory analysis is reevaluated.
5.3.1. All organizations generating HW are responsible for ensuring the update of profile sheets is prepared.
5.3.2. Waste streams should be segregated to as great an extent as practical for a given process.
This ensures proper packaging, marking, labeling, manifesting, and shipping. Waste segregation also aids in recycling efforts.
5.3.3. Waste profiles and waste collection sites will be numbered sequentially by 96
CEG/CEIEC as indicated in Table 5.2
18 EGLINAFBI32-7003 22 APRIL 2015
Table 5.2. Profile and Accumulation Site Numbering System
Waste
Type
Profile Numbering System Waste
Stream
Name
Accumulation Site Numbering
System
HW [YY]HW[4-digit sequential #] [waste stream]
HWI-[bldg#]-[sequential #]
(for IAP)
HW [YY]HW[4-digit sequential #] [waste stream]
HWA-[bldg#]-[sequential #]
(for 45-Day ACCS)
UW [YY]UW[4-digit sequential #] [waste stream]
UW-[bldg#]-[sequential #]
SPW [YY]SPW[4-digit sequential#] [waste stream]
SPW-[bldg#]-[sequential #]
POL [YY]POL[4-digit sequential#] [waste stream]
POL-[bldg#]-[sequential #]
Note: Some existing profiles may be numbered [YY]HM[4-digit sequential #] or [YY]PCB[4-digit sequential #]
5.3.4. Each initial accumulation point will be assigned only one profile. Generally UW and
SPW sites will also have only one profile assigned, but the hazardous waste manager may make exceptions.
5.3.5. Organizations and/or UECs shall notify 96 CEG/CEIEC if more than one profile is assigned per initial accumulation point.
5.3.6. If feedback received by the HW disposal services contractor or DRMO indicates the generator’s waste identification is incorrect/inaccurate, a verification testing program for wastes received from that generator will be initiated. This testing will begin on the next turn-in by this generator and will continue until the generator’s identification has been proven accurate.
5.4. Hazardous Waste Inventory. The inventory of HW generated is maintained in EESOH-
MIS.
5.5. Abandoned Waste. Notify your UEC immediately if you find abandoned containers and/or waste. All unmarked containers are suspected waste. If the organization in the immediate vicinity cannot confirm the contents of an unmarked container, the organization shall immediately handle the container as if it is a hazardous waste. This includes marking, labeling, dating the container, and keeping the container closed except for sampling. The container contents will be analyzed to determine the appropriate characterization, and the date of sampling will be marked on the container. Upon receipt of test results, the waste will be characterized and the appropriate type of site management requirements will be applied.
5.5.1. Ensure all usable material is stored and marked properly, so that it will not be mistaken for abandoned waste.
5.5.2. It is good practice to mark empty containers being stored for later use as empty.
Containers being stored shall be stored in a manner that prevents collection of rain water in order to avoid the collected rain water being suspected as abandoned waste.
EGLINAFBI32-7003 22 APRIL 2015 19
Chapter 6
HAZARDOUS WASTE ACCUMULATION SITE OPERATIONS
6.1. Container Tracking System. A waste and material tracking system has been implemented through the EESOH-MIS. All waste containers are tracked through the Container Number (CN) identified on the waste description label (non-hazardous and hazardous wastes) provided by the waste disposal services contractor.
6.2. Types of Storage Areas.
6.2.1. An accumulation site (ACCS) is an organization’s central accumulation site for hazardous waste at which an unlimited amount of HW can be accumulated for up to 45 days.
Some sites may be authorized up to 90 days.
6.2.1.1. An initial accumulation point (IAP) is an area at or near the point of generation of the waste at which no more than 55 gallons of HW or 1 quart of acute HW can be accumulated. Each IAP is authorized to collect a single waste stream. IAPs can be established in close proximity to each other, but each must collect a different waste stream and be operated as an individual site. If waste generation is intermittent, IAPs can be activated and deactivated as mission needs require by coordination between the generator, UEC, and 96 CEG/CEIEC.
6.2.1.2. UW, SPW, and used oil management requirements are described in Chapter 7.
6.3. Accumulation Container Management.
6.3.1. Containers must be in good physical condition.
6.3.2. Containers accumulating HW, UW, or SPW that do not contain free liquids are recommended to be located on a concrete pad, pallet, or other supporting structure that keeps the container from contact with the soil.
6.3.3. Containers that contain free liquids must be placed in an area with secondary containment when accumulating HW, UW, or SPW. The containment system must have sufficient capacity to contain 10% of the volume of all containers or the volume of the largest container, whichever is greater. Special containment pallets are less expensive than building dikes/berms and are portable. Note: Aerosol containers and intact battery casings are a primary container; the collection drum is considered secondary containment. Any spilled material must not be able to flow into a storm drain, sewer, or onto permeable surfaces.
6.3.4. Containers must not be located near anything with which the waste may be incompatible
(for example an acid stored next to a caustic). This may be accomplished by physically separating the waste containers by means of a dike, berm, wall, or use of a containment pallet for each incompatible HW.
6.3.5. Adequate aisle space (no less than 3 feet) must be maintained to allow the unobstructed movement of personnel and fire protection, spill control, and decontamination equipment.
Container markings and labels must be visible from the aisle.
6.3.6. It is a regulatory requirement that accumulation containers must always be kept closed unless waste is being added to or removed from the container. For a container to be considered
20 EGLINAFBI32-7003 22 APRIL 2015
closed, fastening rings must be in-place and properly secured. For bung type drums, bungs must be closed and capped tight. Containers must not leak if overturned.
6.3.7. Containers must not be handled, stored, or opened in a manner which may rupture the container or cause it to leak.
6.3.8. The HW disposal services contractor will provide containers approved per DOT performance oriented packaging regulations.
6.3.9. Select the container size that best suits your needs. Do not overfill containers; fill to
90% capacity.
6.3.10. The type of waste being accumulated must be identified to ensure container/waste compatibility. The container must be compatible or lined with material that is compatible with the hazardous waste to be stored, so that the integrity of the container is not impaired.
6.3.11. Only DOT approved containers will be used for HW, UW, and SPW.
6.3.12. Containers must be marked and labeled (including DOT) as appropriate for their content.
6.3.13. HW marking labels must contain the following information:
6.3.13.1. Generator’s name and address; Eglin AFB, DRMO, Building 525, Transportation Road Eglin AFB FL, 32542.
6.3.13.2. “Hazardous Waste! Federal Law Prohibits Improper Disposal. If found, contact the nearest police, public safety authority, or the US Environmental Protection Agency
(EPA).”
6.3.13.3. EPA ID number; “FL8570024366.”
6.3.13.4. The EPA waste code(s), which will vary depending upon the waste. The waste code(s) is on the DRMS Form 1930 or EESOH-MIS equivalent, HW Profile Sheet.
6.3.13.5. The DOT Proper Shipping Name (PSN). The PSN is on the DRMS Form 1930 or EESOH-MIS equivalent, HW Profile Sheet.
EGLINAFBI32-7003 22 APRIL 2015 21
Figure 6.1. Hazardous Waste Label
6.3.13.6. The date and storage time depends on the site type.
6.3.13.6.1. An IAP has no time limit for accumulation of HW until the container is full. The accumulation start date on the label at an IAP should be marked with the date that the container becomes full (55 gallons or less). The waste must be moved to an
ACCS within 3 days of marking the accumulation start date on the full container.
During the 3-day period, the generator must continue to comply with the conditions of
Paragraphs 6.3 and 6.4
6.3.13.6.2. A generator may accumulate any amount of HW in containers at an ACCS for up to 45 days. (The High Explosives Research and Development (HERD) facility will have up to 90 days to accumulate on site, because their waste is treated at Eglin.)
Drums placed in a 45-day ACCS will be dated upon entry into the storage area unless already dated due to relocation from an IAP.
6.3.14. If hazardous material products in their original containers are turned into an ACCS as a hazardous waste, they may be temporarily stored in the original container provided the container is in good condition, is less than 26 gallons, and is marked with the words “Hazardous
Waste” and dated upon storage. Compatible items may be placed in a container marked
“Hazardous Waste” and dated. These waste products shall be characterized and transferred to properly marked and labeled DOT approved containers at the earliest opportunity. The accumulation start date marked on the product container shall be transferred to the DOT approved container. Empty product containers shall be recycled if possible, or disposed in refuse.
22 EGLINAFBI32-7003 22 APRIL 2015
6.4. Operating Procedures.
6.4.1. A current listing of approved waste accumulation areas is available through EESOH-
MIS.
6.4.2. 96 CEG/CEIEC must approve collection and handling of any waste stream by the waste disposal contractor.
6.4.3. Storage of more than 55 gallons of HW in a single IAP for longer than 3 days is prohibited.
6.4.4. The UEC will coordinate with 96 CEG/CEIEC to establish, modify, or close an IAP or
ACCS. CEIEC will authorize the site and enter the site data into EESOH-MIS. The following information is required:
6.4.4.1. Proposed site location (building number, range number, etc.).
6.4.4.2. A copy of the site-specific spill plan.
6.4.4.3. Name of primary and alternate site managers, supervisor of site manager, and their phone numbers.
6.4.4.4. Description of waste(s) generated.
6.4.4.5. Description of the process(s) generating the waste(s).
6.4.4.6. Appropriate SDS numbers, SDS, or product technical information.
6.4.5. The IAP or ACCS site manager and an alternate are responsible for ensuring that all regulatory requirements are met, such as container marking and labeling, training, and record-keeping.
6.4.6. 96 CEG/CEIEC will assign an accumulation site number as described in Table 5.2.
6.4.7. IAP and ACCS site postings and records requirements are identified in Table 6.1. Signs at IAP and ACCS must identify the IAP or ACCS manager, the alternate, their phone numbers, and the site identification number. All site records must be maintained for 3 years after site closes.
Table 6.1. IAP and ACCS Postings and Records
Description Visual Site
Posting
Site Records
(readily available)
This instruction X
Training Records X
DRMS Form 1930 or EESOH-MIS equivalent, HW
Profile Sheets
X
Daily Operational Checklist X
Sign X
Site-specific spill plan X
Completed Inspection Checklists (ACCS only) X
EGLINAFBI32-7003 22 APRIL 2015 23
6.4.8. ACCS inspections will occur and be documented by the ACCS manager or alternate weekly. Weekly means there will be a documented inspection at least every 7 days. At a minimum, inspection documentation shall include the date and time of the inspection, the legibly printed name of the inspector, the number of containers, the condition of the containers, a notation of the observations made, and the date and nature of any repairs or other remedial actions. Maintain recent (6 months) ACCS inspection checklists at the site. Documentation of weekly site inspections is not required at an IAP. However, IAP managers should inspect their sites as needed to maintain compliance. Documentation of these inspections is recommended but not required.
6.4.9. It is good management practice for IAP and ACCS managers or alternates to walk through the areas daily to ensure containers are closed and are not leaking or handled improperly.
6.4.10. IAPs shall be located at or near the point of waste generation and be under the control of the operator of the process generating the waste. ACCSs will be under the control of the site manager and alternate. Implement appropriate controls to limit access to authorized users.
6.4.11. Post “No Smoking” signs when there is a hazard from ignitable or reactive wastes.
Store ignitable or reactive waste no less than 50 feet away from sources of ignition, sparks, and the installation boundary. Note: In accordance with AFOSHSTD 91-501, Air Force
Consolidated Occupational Safety Standard, the transfer of flammable liquids (closed cup flash point below 100°F) from one container to another shall be done with containers electrically interconnected (bonded).
6.5. Turn-In Requirements and Procedures.
6.5.1. DRMO is responsible for disposal of all HW/HM except for the wastes identified in
Table 6.2.
6.5.2. HW must be turned in before the end of the allowed accumulation time or allowed quantity is exceeded.
6.5.3. All transfers and turn-ins of HW must be conducted under the direction of 96
CEG/CEIEC and processed through the waste disposal services contractor. Waivers for waste transfer and disposal or recycling services must be obtained from 96 CEG/CEIEC prior to arranging for and transferring waste to a non-DRMO waste disposal services contractor.
6.5.4. Contact the HW disposal services contractor (882-7664) to initiate the turn-in process.
The HW disposal services contractor will generate the DD Form 1348-1A.
6.5.5. Ensure DRMS Form 1930 or EESOH-MIS equivalent, HW Profile Sheet accurately describes the HW stream and has been signed by the generator (site manager or alternate). It is the responsibility of the UEC to request waste profile re-authorization from 96 CEG/CEIEC if there have been any process changes. Chapter 5 provides details on waste determination and profiling requirements.
6.5.6. Unopened or unused serviceable HM that is no longer needed shall be identified to the
Hazardous Material Cell (HMC) as soon as the material is determined to be excess. Special requirements for HM turn-in are described in Paragraph 12.7.
6.5.7. Empty containers should be recycled through the Eglin Recycling Center when feasible. Otherwise, discard empty containers in general refuse.
24 EGLINAFBI32-7003 22 APRIL 2015
6.5.7.1. In order for a container to be considered empty, all material must have been removed that can be removed using commonly employed methods (e.g., pouring,…
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