Hazardous_Waste_Management_Plan_2012.pdf

OPR: 325 CES/CEAN

HAZARDOUS

WASTE

MANAGEMENT

PLAN

Printed versions of document must be considered for reference only. Current document is available on Tyndall’s Hazardous Waste eDASH Website (HWEW) at https://eis.af.mil/cs/edash/aetc/tyndall/Pages%20%20Program%20Areas/Hazardous%20W aste.aspx

Change 1, 18 May 12 https://eis.af.mil/cs/edash/aetc/tyndall/Pages%20%20Program%20Areas/Hazardous%20Waste.aspx https://eis.af.mil/cs/edash/aetc/tyndall/Pages%20%20Program%20Areas/Hazardous%20Waste.aspx i

Tyndall Air Force Base Emergency Reporting and Information Numbers

REPORT ON-BASE EMERGENCIES TO

(fires, explosions, releases, or spills)

Fire and Emergency Services (850) 283-4777) or dial 911

REPORT OFF-BASE EMERGENCIES INVOLVING AIR FORCE ASSETS TO

(fires, explosions, releases, or spills of hazardous waste off-base) # 1. Local Emergency Reporting Number 911 # 2. Command Post 283-2155

FOR CHEMICAL EMERGENCY INFORMATION AND ASSISTANCE

CHEMTREC 800-424-9300

FOR FEDERAL, STATE, AND LOCAL RELEASE NOTIFICATION/REPORTING

National Response Center (800)-424-8802 USEPA Region IV (404)-347-4062 Florida DEP (850)-872-7650 Bay County Emergency Mgmt. Div. (850)-784-4000

FOR AIR FORCE RELEASE REPORTING TO MAJCOM AETC

Command Post DSN 574-7771 Environmental Staff Office DSN 574-4430/7844

EMERGENCY COORDINATOR INFORMATION

Names Title Address Work Number Phone Number (24 Hours) Charles Cain Fire Chief 610 Amberjack Dr. (850) 283-2853 (850) 625-3318 Panama City Beach FL 32413

SMSgt Chris Deputy 3150B Tiger St. (850) 283-2852 (850) 596-3922 Raynor Fire Chief Tyndall AFB FL 32403

Note: Tyndall AFB operates 24 hours. The emergency communication center is located at building 214, Fire and Emergency Services (850) 283-4777.

FOR OFF-BASE ASSISTANCE AND INFORMATION

EPA RCRA/Superfund Hotline 800-424-9346 EPA Hazardous Waste Ombudsman Program 800-262-7937 EPA Emergency Planning & Community Right-to-Know Information Hotline 800-677-9424 EPA Region IV 404-347-3016 State Hazardous Waste Regulatory Authority 850-488-0300 ii

RECORD OF CHANGES

CHANGE NUMBER DATE ENTERED POSTED BY

1 18 May 12 D. Surber

RECORD OF ANNUAL REVIEW

REVIEWED BY DATE REVIEWED REMARKS

D. Surber Jan 12

TABLE OF CONTENTS

Emergency Reporting and Information Numbers ..................................................................... i

Record of Changes ................................................................................................................... ii

SECTION 1 INTRODUCTION

1.1 Objective

1.2 Effective Dates

1.3 Implementation

1.4 Applicability to Tyndall AFB

1.5 Applicability of State Requirements

SECTION 2 RESPONSIBILITIES

2.1 Overview

2.2 325th Fighter Wing / Vice Commander (325 FW/CV)

2.3 325th Civil Engineer Squadron (325 CES)

2.4 325th Civil Engineer Squadron / Environmental Element

(325 CES/CEAN)

2.5 325th Aeromedical Dental Squadron / Bioenvironmental

Engineering Flight

(325 ADS/SGPB)

2.6 325th Fighter Wing / Public Affairs Office (325 FW/PA)

2.7 Commanders of Generating Activities

2.8 Hazardous Waste Accumulation Site Manager

2.9 Hazardous Waste Accumulation Point Manager

2.10 Defense Reutilization and Marketing Office (DRMO)

2.11 325th Fighter Wing / Safety (325 FW/SE) Figure 2.1 Tyndall AFB Hazardous Waste Management Information Flow 18

SECTION 3 TYNDALL AIR FORCE BASE HAZARDOUS WASTE

STREAM LOCATIONS AND INVENTORY

3.1 Hazardous Waste Accumulation Areas (Points and Sites)

3.2 Responsibilities

3.3 Tyndall Air Force Base Hazardous Waste Stream Inventory

Table 3.1 Hazardous Waste Process Codes 21 Table 3.2 EPA Priority Pollutants 22

SECTION 4 TYNDALL AIR FORCE BASE WASTE ANALYSIS PLAN

4.1 Background Information

4.2 Hazardous Waste Characterization Process

4.3 Test Methods Used

4.4 Analytical Methods

4.5 Hazardous Waste Sampling Methods

4.6 Sample Analysis Frequency

4.7 Sample Documentation

4.8 Sample Analysis Request Procedures

4.9 Hazardous Waste Profile Sheet

4.10 Waste Analysis Plan Revision

Table 4.1 Waste Analysis Parameters 34 Table 4.2 Maximum Concentrations of Contaminants for the Toxicity Characteristic 40 Table 4.3 Hazardous Waste from Non-Specific Sources (F001- F005) 41 Table 4.4 Table of Analytical Methods and SW-846 Numbers 42 Table 4.5 Representative Sampling Method Procedures 43 Table 4.6 Waste Sampling Plan 44 Table 4.7 Sample Containerization, Preservation, and Holding Times Figure 4.1 Hazardous Waste Profile Sheet 49 Figure 4.2 Chain of Custody Record 51

SECTION 5 TYNDALL AIR FORCE BASE HAZARDOUS WASTE

MANAGEMENT PROCEDURES

5.1 Specific Waste Management Procedures

5.2 Permitted Storage Facility

5.3 Accumulation Site Management

5.4 Preparedness and Prevention

5.5 Accumulation Point Management

5.6 On-Installation Transportation

5.7 Record Keeping

5.8 Reporting

5.9 Special Waste Management Procedures

5.10 Contractor Inspections

Table 5.1 Accumulation Site Checklist 66 Table 5.2 Accumulation Point Checklist 68 Table 5.3 RCRA Records and Corresponding Minimum Retention Periods 71 Table 5.4 File Locations 72 Figure 5.1 EPA Hazardous Waste Markings 73

SECTION 6 TRAINING

6.1 Personnel for Which Training is Mandatory

6.2 Training Frequency

6.3 Training Components

6.4 Air Force Hazardous Waste Management Training Program

6.5 Required Records

Table 6.1 Hazardous Waste Training Matrix 77

SECTION 7 RESPONSE TO EMERGENCIES

7.1 Emergency Response Procedures and Contingency Plan

Requirements

7.2 Implementation

7.3 Spill Response Equipment

7.4 Handling, Disposal, Spill Containment, and cleanup Procedures for

Fluorescent Lights, Mercury Containing Lights and/or Devices…

SECTION 8 POLLUTION PREVENTION

8.1 Pollution Prevention Program Plan

8.2 Scope of the Pollution Prevention Program Plan

APPENDIX A GUIDELINES FOR INCOMPATIBLE MATERIALS

APPENDX B ACRONYM AND DEFINITION OF TERMAPPENDIX CUNIVERSAL WASTE LABEL

AETC HEADQUARTERS, 325TH FIGHTER WING

TYNDALL AIR FORCE BASE FLORIDA 32403-5541

CHAPTER 1

INTRODUCTION

Section A--Background

1.1. Objective. This document provides a management plan for personnel involved with hazardous waste, providing the essential tools for effective management for compliance with federal and state of Florida legislation and regulations. This plan implements AFI 32-7042, Waste Management, dated 21 April 2009. The purpose of this plan is to establish procedures to be followed by Tyndall Air Force Base (AFB) personnel and special organizations, tenants, and contractors in managing hazardous wastes on Tyndall

AFB.

1.2. Effective Dates

1.2.1. On May 19, 1980, the U.S. Environmental Protection Agency (EPA) published the Hazardous Waste Management System rules. Subtitle C of the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act of 1976 (RCRA), directed the EPA to promulgate these rules and regulations to protect human health and the environment from the improper management of hazardous waste. The effective date of these regulations was November 19, 1980, amended in 1984. The amendments required increased management of hazardous waste by all organizations on Tyndall AFB.

Hazardous wastes in the State of Florida are regulated under authority granted to the State by the USEPA.

1.2.2. The Federal Facility Compliance Act (FFCA) of 1992 requires all DoD facilities to comply with all applicable federal, state, interstate, and local environmental regulations and allows federal and state agencies to assess fines against DoD facilities with RCRA violations.

1.2.3. The Hazardous Waste Management Program for Tyndall AFB began in September, 1978. Based upon previous inventories of all wastes generated on base, it has been determined that Tyndall AFB is a Large Quantity Generator (LQG) under the 1984 amendments to RCRA. Tyndall AFB applied to Florida Department of Environmental Protection (DEP) for an EPA Generator Identification Number in June 1980. EPA ID Number FL1570024124 was issued to Tyndall AFB.

1.3. Implementation

1.3.1. Implementation of the comprehensive Hazardous Waste Management Program mandated by RCRA requires maximum cooperation of all activities on Tyndall AFB. It is the responsibility of the installation commander to ensure compliance with all RCRA requirements for Tyndall AFB and to notify, apply for permits, and report to Region IV EPA or Florida DEP, as required, for all installation activities, including tenant activities.

1.3.2. The individual base operational units (generating activities) are accountable for conducting their activities in accordance with this plan. Those base units, including tenant activities, will provide necessary documentation to the installation commander through the Environmental, Safety, and Occupational Health Council (ESOHC) for permit application, provide the reports required by Region IV EPA or Florida DEP, and ensure compliance with RCRA regulations and permit requirements at the facility. Plan revisions shall reflect changes in either level of hazardous waste management laws and regulations. Each revision to this plan will become effective immediately upon distribution unless otherwise noted herein.

Section B--Scope of the Hazardous Waste Management Program

1.4. Applicability to Tyndall AFB

1.4.1. This plan applies to all Tyndall AFB organizations, tenants or contractors doing business within the confines of Tyndall AFB who generate, store, treat, or dispose of hazardous waste. The plan covers the control and management of hazardous wastes at the point where they are generated from hazardous materials to the point of ultimate disposal. This plan is intended to comply with EPA’s regulations as contained in the Code of Federal Regulations (CFR), Title 40, Parts 261 through 280.

1.4.2. Information in support of this plan was obtained through conversation with Tyndall AFB personnel, accumulation point managers, Civil Engineer/Environmental personnel (CEAN), and shop tenants to provide a comprehensive listing of potential hazardous and special wastes generated by the respective facility. This review included recycled and reclaimed materials.

1.4.3. Generator responsibility for managing hazardous wastes and procedures being implemented for accumulation and disposition of these wastes were reviewed for contingency purposes of this plan.

1.4.4. Waste materials classified as non-hazardous, such as petroleum, oils, and lubricants (POL) waste streams, were also reviewed to note current procedures being implemented for disposition of these products.

1.4.5. Contract services for handling, documenting, and transporting of hazardous waste for off-site disposal was reviewed for this plan.

1.4.6. Personnel training/requirements as stipulated in 40 CFR 262.34 (a) (5) and 264.16 are addressed in this plan to provide proper instructions to shop personnel for managing hazardous waste. Implementation of emergency procedures as outlined in the Hazardous Material Plan (HAZMAT Plan) is also addressed to supply shop personnel with necessary emergency procedures relative to their workplace.

1.5. Applicability of State Requirements. This plan also addresses mandatory requirements of the State of Florida DEP Regulations, Chapter 62-730, Hazardous Waste Rules. This plan is intended to comply with Florida DEP regulations for hazardous waste. Florida DEP serves as the judicial power for issuing operating permits and enforcing hazardous waste regulations. Tyndall AFB is not exempt from state regulations which have been authorized by EPA to implement RCRA requirements.

CHAPTER 2

RESPONSIBILITIES

Section A--Tasked Organizations

2.1. Overview

2.1.1. Responsibilities for implementing this plan are distributed throughout base organizations that generate, accumulate, store, transport, turn-in, monitor, dispose of, or respond to incidents involving hazardous waste. Hazardous waste is not treated on Tyndall AFB; therefore, regulations related to treatment of hazardous waste are not applicable. Compliance with federal, state of Florida, and local hazardous waste laws and regulations is the responsibility of the installation commander through the Environmental Safety Occupational Health Counsel (ESOHC).

2.1.2. The following organizations are tasked under this plan: 325th Fighter Wing Vice Commander, (ESOHC Chairperson); 325th Civil Engineer Squadron; 325th Logistics Readiness Division (Materiel Management, Fuels Management, and Vehicle Management); 325th Medical Group; 325 Maintenance Group (AMXS, MXS, MOS, DS2, AFETS, AFREP Transit Alert); 325th Communications Squadron; 325th Force Support Squadron; AFCESA/CEMIRT; Lockheed Martin Services Inc.; AIR 1ST; and Air Force Research Laboratory (RXQ). Organizations that have specific responsibilities for the hazardous waste management program as well as those organizations that handle hazardous waste are described in Section B. Figure 2.1 presents the Tyndall Organizational Chart including major tenants which may be tasked with responsibilities in the Hazardous Waste Management Plan.

Section BSpecific Responsibilities

2.2. 325th Fighter Wing / Vice Commander (325 FW/CV)

2.2.1. Serves as ESOHC Chairperson.

2.2.2. Ensures that management of hazardous waste on Tyndall AFB complies with applicable portions of 40 CFR Parts 260-271 and State of Florida Hazardous Waste Management Regulations (Chapter 62-730).

2.2.3. Ensures the hazardous waste management plan is reviewed and approved at least annually. The 325 FW/CC has delegated to the 325th Civil Engineer Squadron Commander the authority to review and approve the Hazardous Waste Management Plan.

2.2.4. Signs installation hazardous waste permit applications.

2.2.5. Ensures all hazardous waste manifests are signed.

2.2.6. Ensures all personnel involved with hazardous waste have the required training and receive refresher training.

2.2.7. Ensures all enforcement actions are resolved within the regulatory time frame.

2.3. 325th Civil Engineer Squadron (325 CES/CC)

2.3.1. Provides emergency notification through the emergency reporting number maintained by the Fire and Emergency Services Flight.

2.3.2. Reviews and signs the hazardous waste management plan record of annual review.

2.3.3. Ensures the hazardous waste management training is provided annually.

2.3.4. Equips the installation hazardous materials (HAZMAT) response team.

2.4. 325th Civil Engineer Squadron / Environmental Element (325

CES/CEAN)

2.4.1. Environmental Manager for the base hazardous waste program.

2.4.2. Updates the hazardous waste management plan.

2.4.3. Conducts or coordinates hazardous waste management training for all base personnel who handle or who may be otherwise involved in the management of hazardous waste. Maintains training documentation for a minimum of 3 years.

2.4.4. Signs hazardous waste manifests and prepares hazardous waste reports and compliance documentation as required by EPA, Florida DEP, and Air Force instructions.

2.4.5. Performs hazardous waste management compliance surveys of Tyndall AFB properties.

2.4.6. Maintains records of hazardous waste management surveys of Tyndall AFB properties.

2.4.7. Prepares and submits reports to the EPA and Florida DEP.

2.4.8. Coordinates with federal, Florida DEP, and Bay County authorities on hazardous waste management procedures.

2.4.9. Prepares permit applications as required. Coordinates permit applications with

325 FW/CV.

2.4.10. 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:

2.4.10.1. Facility layout plan.

2.4.10.2. Location of each facility that generates hazardous waste and the quantity of wastes at each accumulation point.

2.4.10.3. Records and results of waste analysis and trial tests.

2.4.10.4. Summary reports and details of all incidents that require implementing the hazardous waste contingency portion of the installation's HAZMAT plan.

2.4.10.5. Records and results of inspections.

2.4.11. Provides all applicable records to authorized representatives of the EPA Region IV or Florida DEP.

2.4.12. Maintains routine liaison with HQ MAJCOM, EPA Region IV, and Florida DEP in regard to hazardous waste inspections, rule interpretation, and problem resolution.

2.4.13. Assists waste generating activities in hazardous waste characterization (identification, description, and quantification), accumulation, storage, marking and labeling, waste minimization, waste recycling, waste turn-in, and disposal.

2.4.14. Ensures all hazardous waste is accurately weighed for disposal actions.

2.4.15. Ensures funding requirements are identified and allocates funds based upon regulatory requirements.

2.4.16. Completes and updates DRMS Form 1930,Hazardous Waste Profile Sheet, for all waste streams.

2.4.17. Inspects treatment, storage and disposal facilities (TSDFs) where waste is taken by disposal contractor.

2.5. 325th Aerospace Medicine Squadron / Bioenvironmental Engineering Flight (325 AMDS/SGPB)

2.5.1. Conducts Health Risk Assessments (HRA) on government personnel working in processes generating hazardous wastes. Conducts exposure sampling when required. If bulk sampling is required as part of the HRA, will coordinate with CEAN on analysis, and provide results of analysis to CEAN in support of hazardous waste determination.

2.5.2. If applicable, forwards analytical results to appropriate generating activity and Environmental Manager.

2.5.3. Receives and reviews Materials Safety Data Sheets (MSDSs) for all current and new hazardous materials on the installation.

2.5.4. Specifies and fit personal protective equipment to be worn by government personnel occupationally exposed to or who may otherwise manage hazardous waste (Based on exposure, need, and when no feasible administrative and engineering controls are in place).

2.5.5. Responds to hazardous waste incident or accident when requested by the incident commander

2.6. 325th Fighter Wing / Public Affairs Office (325 FW/PA)

2.6.1. 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.

2.6.2. Assists the On-Scene 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.

2.6.2.1. 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 without permission from the On-Scene Commander.

2.7. Commanders/ Program Managers of Generating Activities

2.7.1. Coordinates with 325 CES/CEAN to ensure that all wastes are evaluated and that hazardous wastes are properly characterized.

2.7.2. Provides safe equipment and locations for accumulation points and accumulation sites. Coordinate each location with Environmental Manager, Ground Safety, Fire and Emergency Services Flight, and Bioenvironmental Engineering Flight (BEF), 325 AMDS/SGGB.

2.7.3. Ensures that the management of hazardous waste accumulation points and accumulation sites, including accumulation, storage and inspection, complies with federal and Florida DEP hazardous waste management regulations.

2.7.4. Appoints an accumulation point manager for shops that generate hazardous waste.

The accumulation point manager retains overall responsibility for the management of the accumulation point. For military supervisors, management duties may be delegated by the shop supervisor.

2.7.5. Accumulation point manager maintains a Hazardous Waste Compliance Folder which contains:

2.7.5.1 Appointment letter from the commander

2.7.5.2 Turn-in documents, provided when waste is transferred to Building 6011

2.7.5.3 The hazardous waste profile sheets provided by CEAN for their waste streams

2.7.5.4 Analytical results/hazardous waste interpretation (sampling)

2.7.5.5 Inspection logs

2.7.5.6 Training certificates for personnel in shops and management

2.7.6. Allows appropriate facilities, shops, and equipment to be inspected for hazardous waste management regulatory compliance by installation fire, safety and health personnel, CEAN personnel, ESOHCAMP team members, and authorized state or federal inspectors.

2.7.7. Ensures all assigned personnel that handle hazardous waste or who are otherwise involved in hazardous waste management and their supervisors receive annual and refresher training.

2.8. Hazardous Waste Accumulation Site Manager

2.8.1. Assumes overall responsibility for management of the hazardous waste accumulation site and accumulation points under their responsibility.

2.8.2. Ensures accumulation sites have appropriate warning signs.

2.8.3. Ensures that the accumulation sites have an emergency response spill kit.

2.8.4. Ensures that an approved fire extinguisher is readily available if flammable hazardous waste is handled at an initial accumulation point or stored in the accumulation sites.

2.8.5. Performs and documents inspections of the accumulation sites. Inspections must be performed weekly for containers and daily for tanks (over 110 gallon capacity).

2.8.6. Ensures that hazardous wastes are collected and stored in approved containers.

2.8.7. Ensures that hazardous wastes are in appropriate (authorized) containers capable of being loaded and transported.

2.8.8. Maintains hazardous waste containers in proper condition, e.g., no pitting, no sharp edge creases or otherwise compromised, no material defects, no bulging heads.

2.8.9. Ensures that containers are kept closed except when they are being filled.

2.8.10. Ensures that all hazardous waste is placed in the approved accumulation site.

2.8.11. Ensures that hazardous waste containers are properly marked before they receive any hazardous waste, which include:

2.8.11.1 Waste description

2.8.11.2 Accumulation start date (the date that the first amount of hazardous waste was placed into the container at accumulation sites; or when the volume limit was met at initial accumulation points)

2.8.11.3 The Tyndall AFB assigned container number

2.8.12. Ensures the creation of a hazardous waste turn in document when any new hazardous waste is received in the accumulation site.

2.8.13. Ensures that the storage of hazardous waste in the accumulation site does not exceed 90 days.

2.8.14. Implements emergency response. Determines severity of a spill. Advises On-scene Commander and determines response necessary for containment and recovery.

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

2.9. Hazardous Waste Accumulation Point Manager.

2.9.1. Ensures the hazardous waste procedures outlined in Section 5.5 of this plan are executed.

2.9.2. Assumes overall responsibility for management of the hazardous waste accumulation points under their responsibility

2.9.3. Ensures accumulation points have appropriate warning signs.

2.9.4. Performs and documents inspections of the accumulation points. Inspections must be performed monthly.

2.9.5. Ensures that hazardous wastes are collected and stored in approved containers.

2.9.6. Ensures that hazardous wastes are in appropriate (authorized) containers capable of being loaded and transported.

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

2.9.8. Ensures that containers are kept closed except when they are being filled.

2.9.9. Ensures that all hazardous waste is placed in an approved accumulation point.

2.9.10. Ensures that hazardous waste containers are marked with the words “Hazardous Waste” and the name of the waste, proper shipping or common name is acceptable, before they are placed in service. Hazardous Waste labels are available at the Hazardous Waste Warehouse (Building 6011).

2.9.11. Provides site specific hazardous waste management training to personnel who handle hazardous waste.

2.10. Defense Reutilization and Marketing Office (DRMO). Ensure hazardous waste is disposed in accordance with state and federal regulation.

2.11. 325th Fighter Wing / Safety (325 FW/SE). Inspects hazardous waste accumulation sites and points during the annual ground safety inspection. All discrepancies discovered will be documented on the formal report.

Section C--Organization Chart Figure 2.1 graphically describes organizational information flow regarding hazardous waste management.

INSTALLATION

COMMANDER

PUBLIC

AFFAIRS

CIVIL ENGINEER

ENVIRONMENTAL

MANAGER

BIOENVIRONMENTAL

ENGINEER

GROUND

SAFETY

ACCUMULATION

SITE MANAGER

ACCUMULATION

POINT SHOP

PERSONNEL

TRANSPORTATION

PERSONNEL

CHAPTER 3

TYNDALL AIR FORCE BASE HAZARDOUS WASTE STREAM

LOCATIONS AND INVENTORY

Section A--Hazardous Waste Locations

3.1. Hazardous Waste Accumulation Areas (Points and Sites)

3.1.1. A hazardous waste accumulation point is an area where waste is accumulated under control of the shop supervisor of the process generating the waste. The shop supervisor or supervised employee is assigned as the hazardous waste accumulation point manager. The maximum volume of hazardous waste permitted at each hazardous waste accumulation point is 55 gallons. Once this limit is exceeded, the waste must be dated and moved to the hazardous waste accumulation site (Building 6011). The areas designated as hazardous waste accumulation points are identified in the Tyndall IAP Summary Report located on HWEW. If an additional hazardous waste accumulation point is needed or changed, a location at or near where the waste is generated will be approved by the Environmental Manager.

3.1.2. A hazardous waste accumulation site is an area where hazardous waste is accumulated in containers for a period of up to 90 days.

Section B--Hazardous Waste Stream Inventory

3.2. Responsibilities

3.2.1. Tyndall AFB maintains a hazardous waste stream inventory (HWSI) for every hazardous waste stream generated on base. CEAN is the office of primary responsibility for the Tyndall AFB HWSI. Tyndall AFB maintains its HWSI in the Air Force’s Enterprise Environmental Safety Occupational Health Management Information System (EESOH-MIS). Tyndall AFB will not handle, store, transport, dispose of or inventory non-DoD owned hazardous wastes or materials except as authorized.

3.2.2. Tyndall AFB will ensure that all wastes are properly characterized and classified as either hazardous or non-hazardous wastes in accordance with the Tyndall AFB Waste Analysis Plan (See Chapter 4). Hazardous wastes will be characterized on the DRMS Form 1930. Information from the hazardous waste profile sheet (HWPS) will be used by CEAN to maintain and update the HWSI. The hazardous waste accumulation site manager is responsible for quantifying all hazardous waste streams for the hazardous waste stream inventory.

3.2.3. Hazardous waste generating activities, with assistance from CEAN will identify and separately document wastes, which are classified as non-hazardous due to the following:

3.2.3.1. Subject to solid or hazardous waste exclusions (40 CFR 261.4)

3.2.3.2. Recycled, not subject to the generator waste determination requirements of 40 CFR § 262.11 (e.g., lead acid batteries that are being reclaimed, used oil that is burned for energy recovery, and scrap metal which is recycled) (40 CFR 261.6)

3.2.3.3. Land disposal restricted waste that is excluded from the definition of hazardous or solid waste or exempt from Subtitle C regulations under 40 CFR 261.2-261.6 subsequent to the point of generation, to document the waste, its exclusion or exemption, and the disposition of the waste

3.2.4. The hazardous waste generating activity of an area generating an excluded, exempt, or recycled waste will place a one-time notice stating such generation, the subsequent exclusion from the definition of solid or hazardous waste or exemption from Subtitle C regulation, and the disposition of the waste in the generating activity's Hazardous Waste Compliance Folder. A copy of the document will be forwarded to the Environmental Manager and from the date the waste was last sent to off-site treatment, storage, or disposal. CEAN will hold a copy of this document for five years.

3.3. Tyndall Air Force Base Hazardous Waste Stream Inventory. Table 3.1 identifies the Hazardous Waste Process Codes used in the waste stream numbers found in the Waste Stream Inventory located in EESOH. This inventory was developed for the hazardous and special waste streams generated by Tyndall AFB.

Table 3-1. Hazardous Waste Process Codes

Process

Description Process Codes

Abrasive Blasting Grit, paint chips, expanded media AB Aircraft Cleaning Cleaning compounds AC Battery Shops Battery acid, lead BA Biological Operations Pesticides such as insecticides, herbicides, rodenticide, etc. BO Boiler Operations Morpholine, nitrates BL Chemical Paint Stripping Paint strippers, paint sludge CP Decarbonizers Nitric acid, sulfuric acid, others DE Avionics/Electronics Solvents ER Electroplating Cleaning compounds, chromium, cyanide, tank sludges contaminated with heavy metals

EP

Expired Shelf Life Expired shelf-life wastes--paints, solvents, cleaning materials, etc. ES Firefighting Operations Aqueous film-forming foam (AFFF) FF Fluids Change-out/ Purging Oily waste, turbine oil, lube oil, hydraulic fluid, contaminated fuel, brake fluid, antifreeze, fluid-containing filters

FC

Industrial and Facility Maintenance

Cleaning supplies, mercury vapor lamp bulbs, PCBs IM

Industrial Operations Tool and machine wastes, cutting oils IO Installation Restoration Waste from clean-up of installation restoration program sites IR Industrial Waste Treatment Wastewater treatment sludge, chlorine IW Laboratory/NDI Samples, test chemicals, penetrants LA Medical Mercury, test chemicals, chemotherapeutic drugs ME Miscellaneous Only wastes which cannot possibly be attributed to any other process listed

MS

Ordnance, demil/disposal Explosive, pyrotechnic, propellant, lead contaminated water, soil or dust

OD

One-Time Only Purging underground storage tank prior to replacement OO Oil Water Separators Contaminated sludge, floating product OS Painting Operations Paint, paint sludge, filters, surface preparation (solvents) PO Preservation and Packaging Pentachlorophenol, copper arsenite PP Photo/X-ray Fixer, developer PX Research and Development Chemical testing, equipment testing RD Spill Clean-up Absorbants, rags, contaminated soil SC Solvents/Degreasing Cold cleaning solvents, PD 680, MEK SO Aerosols Aerosol cans, paint, cleaners, solvents, lubricants XA Automotive Brake pads containing asbestos XP

Table 3-2 EPA Priority Pollutants

Priority Pollutant Air Force Use ID Number

Benzene Fuels 1 Cadmium and Compounds Plating for corrosion control 2 Carbon Tetrachloride Bearing cleaning, PMEL 3 Chloroform Bearing shop 4 Chromium and Compounds Plating and paints 5 Cyanides Plating solutions 6 Dichloromethane Cold wipedown cleaner 7 Lead and Compounds Batteries, paint, solder 8 Mercury and Compounds Laboratories 9 Methyl Ethyl Ketone Degreaser/cleaner, aircraft 10 Methyl Isobutyl Ketone Paints 11 Nickel and Compounds Plating for corrosion control 12 Perchloroethylene Degreaser 13 Toluene Paints 14 Trichloroethane Parts cleaning, propellants 15 Trichloroethylene Degreaser, parts cleaning 16 Xylene Paints 17

CHAPTER 4

TYNDALL AIR FORCE BASE WASTE ANALYSIS PLAN

4.1. Background Information

4.1.1. Federal and State Requirements. This waste analysis plan (WAP) for Tyndall AFB is required by 40 CFR 265.13(a), (b), and (c), 40 CFR 268.7, State of Florida DEP regulations, and Air Force policy. The WAP applies to all Tyndall AFB hazardous waste streams that are transferred to the 90-day storage area at Building 6011. Tyndall AFB does not dispose of, or treat hazardous waste on its property boundaries, so compliance with the waste analysis requirements of 40 CFR 268.7(a)(4) is not required.

4.1.2. Tyndall AFB Plan Contents. The WAP is intended to comply with federal and Florida DEP RCRA requirements and includes specific requirements for the identification and evaluation of hazardous wastes at the base. The WAP describes detailed procedures for documenting generator knowledge of processes to characterize wastes or by obtaining physical and chemical analyses from all associated waste generating activities at Tyndall AFB. This includes procedures for selecting waste parameters for analysis, selecting waste sampling methods, documenting samples, identifying analytical methods, selecting facilities for analyzing samples, and reevaluating hazardous waste streams. The plan contains base procedures for identifying and evaluating hazardous waste streams in order to complete a hazardous waste profile sheet on each hazardous waste stream.

4.1.3. Waste Stream Inventory. The Tyndall AFB HWSI is located in EESOH as specific hazardous waste profile sheets for shops specific waste streams identified during evaluation of shop operations. The hazardous waste process codes used in the hazardous waste stream inventory can be cross-referenced to the WAP procedures to identify the sampling and analytical procedures, which apply to specific hazardous waste streams generated at Tyndall AFB.

4.2. Hazardous Waste Characterization Process. Hazardous waste characterization involves three sequential steps: 1) waste identification, 2) waste description, and 3) waste quantification.

4.2.1. Waste Identification

4.2.1.1. Waste identification is a process in which all wastes generated at Tyndall AFB are evaluated to determine whether the waste is hazardous or non-hazardous. Waste

Identification also involves classifying hazardous wastes. This process can be conducted either by using the waste generator’s knowledge of the waste and process or by analytical testing. In either case, all evaluations must be based on the EPA solid waste and hazardous waste definitions. Analytical testing is required at Tyndall AFB for all waste streams which are chemical mixtures. Testing is not normally required for waste unused commercial chemical products or laboratory chemicals in their original, marked containers.

4.2.1.2. The Environmental Manager will determine if the generator’s knowledge of the waste is sufficient to characterize the waste. The generating activity should request a hazardous waste determination through the Environmental Manager. If testing is needed, CEAN will arrange for sampling and analysis. Sampling and analysis must be conducted in accordance with the requirements specified in EPA publication SW-864 and this WAP.

4.2.1.3. The waste generating activity should ask the following questions to determine if they have a hazardous waste stream which requires further evaluation:

4.2.1.3.1. Is it a waste? If the answer to any of the following four questions is yes, the material is a waste.

4.2.1.3.1.1. Is the material no longer useful for its intended purpose because it is dirty, out of specification, or a spill residue?

4.2.1.3.1.2. Is it an unintended or unusable by product?

4.2.1.3.1.3. Does the base intend to discard the material for eventual treatment, storage, recycling, or disposal?

4.2.1.3.1.4. Is it produced by cleanup at a previously uncontrolled waste site?

4.2.1.3.2. Is it a solid waste? A solid waste is generally defined as any discarded material (including solids, liquids, and containerized gases), which is abandoned, recycled, or considered inherently waste-like.

4.2.1.3.3. Is it a hazardous waste? If the material is a solid waste, the solid waste must be evaluated to determine if it is a hazardous waste. A solid waste is a hazardous waste if it has not been excluded from regulation and is a characteristic hazardous waste (e.g., ignitable, corrosive, reactive, or toxic), a listed hazardous waste, or a mixture of a listed hazardous waste and solid waste. This evaluation can be conducted by either using the waste generator's knowledge of the hazardous characteristics of the waste in light of the materials or processes used, or by analytical testing as described 40 CFR 261 and this

WAP.

4.2.2. Waste Description. The analytical results must be interpreted to determine if tested waste streams are hazardous according to 40 CFR Part 261 or Florida DEP definitions. A copy of these analytical results will be kept on file the Environmental Manager, and the generating activity. CEAN should mark the test results as "HAZARDOUS WASTE" or "NOT HAZARDOUS WASTE" after making a determination. The analytical results, as well as the generating activities waste process knowledge, will be used to complete DRMS Form 1930. The generating activity will obtain assistance in completing the hazardous waste profile sheet from the Environmental Manager. CEAN will prepare DRMS Form 1930with the assistance of the generating activity.

4.2.3. Waste Quantification. The final step is determining the amount of hazardous waste generated each year, which is documented in the hazardous waste inventory. The Tyndall AFB hazardous waste stream inventory lists all hazardous waste streams generated at the base (see Chapter 3).

4.3. Test Methods Used

4.3.1. Waste Stream Screening. Tyndall AFB WAP provides the basis for identifying and characterizing Tyndall AFB hazardous waste streams. All new waste streams must be evaluated by the generating activity as soon as they are generated and prior to leaving the waste generating area.

4.3.2. Waste Parameter Selection

4.3.2.1. EESOH lists all of the existing waste streams at Tyndall AFB by waste stream number and identifies the specific parameters that are analyzed for each waste stream.

Analytical testing for the specified parameters must be repeated annually unless the waste generating process or the materials comprising the wastes change. The waste parameters are based on the suspected hazardous waste characteristics of the waste.

4.3.2.1.1. Flashpoint (Ignitability). Flashpoint is determined through a test procedure, which identifies whether a waste is ignitable (D001). Ignitable hazardous wastes have flashpoint less than 140F. Testing should occur for liquid hazardous waste streams in containers, which contain varying concentrations of ignitable solvents that have the potential to lower the waste's flashpoint to less than 140oF. These wastes must be retested annually because process knowledge is not adequate to accurately predict flashpoint.

4.3.2.1.2. Reactive Waste. Wastes suspected of being reactive must be tested to identify potential reactivity and relevant health and safety precautions. Reactive wastes have the potential to be unstable and may undergo a violent change without detonation; may react violently with water; may form potentially explosive mixtures with watering; may generate quantities of toxic gases, vapors or fumes when mixed with water; may be cyanide or sulfur-bearing which can generate toxic gases, vapors, or fumes when exposed to a strong initiating source or if heated under confinement; may be readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure;

or is a forbidden explosive as defined in 49 CFR 173.52 or a Class A or Class B explosive as defined in 49 CFR 173.53 and 173.88.

4.3.2.1.3. Corrosive Waste. Corrosive waste having the potential to exhibit a pH less than or equal to 2, or greater than or equal to 12.5, must be analyzed for pH. These wastes may degrade unit structures or systems and may require pretreatment. Corrosive wastes are prohibited from land disposal.

4.3.2.1.4. Toxicity Characteristic Leaching Procedure (TCLP). Waste which potentially contains any of the contaminants listed in Table 4.2 should be analyzed for those constituents by the TCLP. When tested in accordance with TCLP, if an extract from a representative sample of waste contains any concentration equal to or greater than the regulatory level listed in the table, the waste is a hazardous waste. Wastes must be retested annually.

4.3.2.1.5. BTU Value and Ash Content. The BTU value and ash content for hazardous waste streams which may be used in an energy recovery program will be analyzed annually to determine if these hazardous waste streams are suitable for fuel blending and use in an energy recovery program. To be accepted, these wastes must have a minimum heating value of 5000 BTU/lb and ash content no higher than 5 percent.

4.3.2.1.6. Listed Wastes. The process and feed stocks will be reviewed annually to determine if any listed wastes are generated. These wastes will be analyzed for the characteristic and constituent parameters required for safe management and disposal.

4.3.2.2. All new and non-recurring hazardous waste streams, except for laboratory chemicals and unused commercial chemical products, must be tested in accordance with the TCLP to determine if they exhibit the toxicity characteristic, except when process knowledge is sufficient to certify that none of the TCLP contaminants could be present.

In addition, the major components of each hazardous waste stream must be defined on the hazardous waste profile sheet. If process knowledge is insufficient, these wastes will be tested to determine their major components. A major component includes any hazardous constituent listed in Appendix VIII of 40 CFR Part 261 present over 10,000 ppm (1%). If process knowledge is insufficient to identify major components, then testing for those components in accordance with the procedures outlined in EPA's Publication SW-846 will be necessary. Additional testing (e.g., flashpoint, BTU value, ash content, pH, etc.) will be based on the testing requirements specified in the disposal contract for the waste.

4.3.2.3. In some cases characteristic waste analyses may not provide enough information, depending on the constituents of the discarded material. Where further analysis is needed for a specific contaminant, methods defined in 40 CFR 261, Appendix III will be requested.

4.3.2.4. EPA has determined that some specific wastes are hazardous. These wastes are incorporated into 40 CFR 261.31-261.33. Listed wastes are divided into three categories:

4.3.2.4.1. Non-Specific Source Wastes - This list includes halogenated organic compounds (HOCs) which are typically found in cleaning and degreasing solvents used for maintenance of aircraft and general purpose equipment. These generic wastes are identified as the “F” listed waste by EPA. A description of “F” listed wastes F001 - F005 are found in Table 4.3.

4.3.2.4.2. Source-Specific Wastes - This list includes waste from specific industries and is identified as the “K” wastes. “K” wastes are not generated at Tyndall AFB.

4.3.2.4.3. Commercial Chemical Products - This list refers to pure grade purchased chemicals, if and when they are discarded or off-specification chemicals, container residues, or accidental spills. The “U” list may apply to Tyndall AFB, as it contains chemicals such as Trichloroethylene (TCE) and toluene. The “P” list contains chemicals designated as acutely toxic wastes which are not currently found on Tyndall AFB.

4.3.2.5. All listed wastes as determined in 40 CFR 261.3, Subpart D, are presumed to be hazardous regardless of their concentrations and must be handled according to the regulations unless delisted under 40 CFR 260.2.

4.3.2.6. Tyndall AFB waste oil, which is recycled off-site by being burned for energy recovery, is not regulated as a hazardous waste. Samples of used oil will be taken annually to ensure the oil meets the standard of 40 CFR 279.11.

4.4. Analytical Methods

4.4.1. Several of the parameters specified above will be analyzed using the test methods from EPA’s “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods" (EPA Publication SW-846). The SW-846 method numbers are specified in Table 4.4.

4.4.2. The hazardous waste analysis for all of the above waste streams will be conducted by a certified laboratory under contract with Tyndall AFB for sampling and analysis of environmental media.

4.5. Hazardous Waste Sampling Methods

4.5.1. All waste samples will be collected in accordance with procedures specified in this WAP and the EPA-specified procedures identified in Table 4.5 to ensure that they are representative of the waste stream. The waste process codes found in the waste stream number used in the hazardous waste stream inventory can be cross-referenced to the WAP procedures to identify the sampling and analytical procedures which apply to specific hazardous waste streams generated at Tyndall AFB.

4.5.2. Determination of the appropriate sampling equipment and sampling procedure depends upon the chemical constituents and physical state of the waste. Examples of appropriate sampling equipment and procedures are listed in Table 4.6. Although there are multiple physical states and different waste sampling procedures for each physical state, only those procedures most appropriate for typical wastes generated are discussed.

4.5.3. Table 4.7 provides containerization information for various parameters to be analyzed.

4.5.4. Sample Types. If the waste is contained in five or fewer containers, every container should be sampled. However, if there are a large number of containers, a subset of containers to be sampled will be chosen randomly by using a random number table. Homogeneous samples of the same waste stream may be composited by the laboratory prior to analysis. Main sample types include grab and composite.

4.5.4.1. Grab Sample. A sample taken from a particular location at a distinct point in time is called a grab sample. This type of sample is useful in determining waste stream variability when multiple or frequent samples are taken. However, this type of sampling may require a larger number of samples than compositing to obtain a representative sample.

4.5.4.2. Composite Sample. A composite sample is a set of individually collected samples that are combined into a single sample for analysis. This is the most common type of sample for obtaining average concentration estimates of a waste stream.

4.5.5. Obtaining Samples of Rags from Containers. Ideally, several samples should be taken from locations dispersed both horizontally and vertically through the open containers. General guidance for obtaining a representative sample based on the container’s volume is as follows:

4.5.5.1. 55-gallon drum. Collect ten rags from ten depth intervals and section into quarters. Composite sample by placing one section from each depth into sample container.

4.5.5.2. 20 to 30-gallon drum. Collect six rags from six depth intervals and section into quarters. Composite sample by placing one section from each depth into sample container.

4.5.5.3. 5-gallon drum. Collect three rags from three depth intervals and section into quarters. Composite sample by placing one section from each depth into sample container.

4.5.5.4. A vertical profile of the container is obtained by inserting the forceps sampler into the waste at the appropriate sample depth, opening the forceps’ jaws on a rag, and retracting the forceps sampler from the container. The removed waste rags are then laid out flat on a clean working surface. Each rag is cut into quarters (1/4) and the lower right quarter of each rag will be placed in the sample container. The sample jar(s), is preserved, if required, sealed, labeled, and placed in an appropriate shipping container(s) for transportation to the laboratory.

4.5.6. Obtaining Samples of Unknown Wastes

4.5.6.1. Safety Precautions. The first phase of obtaining samples of unknown waste is to eliminate any immediate hazard. This includes isolating the area, restricting personnel access, and containing any leaks or spills. Required protective clothing should be identified, as well as any equipment specifications such as the use of non-sparking tools.

A bulging drum indicates that it is under pressure and should not be sampled until pressure is relieved.

4.5.6.2. Initial Screening. Record conditions, markings and observations of containers.

Include any background information on the waste that has been obtained through a records search or personnel interview. The following information describing the physical characteristics of the waste should be recorded:

4.5.6.2.1. Color - Describe the color of the waste (e.g., blue, clear, varies)

4.5.6.2.2. Physical State (e.g., solid, liquid, powder, gas, semi-solid, or sludge)

4.5.6.2.3. Layers - Note whether the waste is multi-layered (e.g., oil/water/sludge), bi-layered (e.g., oil/water) or homogeneous.

4.5.6.2.4. Percent Liquid - Estimate the percent of liquid volume. (The Paint Filter Test, SW 846 Method 9095, must be conducted to confirm that there are no free liquids.)

4.5.7. Equipment Decontamination. Equipment decontamination consists of physically removing contaminants from the sampling equipment by washing with a decontamination solution and rinsing with clean water. The procedure used is determined by evaluating the specific contaminant and reviewing the manufacturer’s recommendations. In all cases, methods to minimize decontamination solution waste and decontamination rinse water generated during this process will be implemented.

4.5.7.1. Decontamination equipment/materials include:

4.5.7.1.2. Soft-bristle scrub brushes and long-handle scrub brushes used to remove contaminants

4.5.7.1.2. Buckets of water or garden sprayers used for rinsing

4.5.7.1.3. Large, galvanized wash tubs, stock tanks or children’s wading pools used as containers for wash and rinse solutions

4.5.7.1.4. Large plastic bags for the storage of contaminated clothing and supplies

4.5.7.1.5. Metal or plastic cans or drums used for the storage of contaminated rinseate liquids

4.5.7.1.5. Paper or cloth towels used for drying equipment, if necessary.

4.5.7.2. A general decontamination procedure is provided below. Modification to this method and use of differing decontamination solutions are determined by 325 AMDS/SGPB prior to sampling.

4.5.7.2.1. Disassemble sampling apparatus, if necessary

4.5.7.2.2. Clean each part with a scrub brush and the appropriate decontamination solution

4.5.7.2.3. Triple rinse with potable water

4.5.7.2.4. Rinse with…