Attachment 1U - Tyndall Hazardous Waste Management Plan.pdf

U. S. AIR FORCE HAZARDOUS WASTE MANAGEMENT PLAN

325th Fighter Wing

10/30/2018

About This Plan

This installation-specific Environmental Management Plan (EMP) is based on the U.S. Air Force’s (AF) standardized Hazardous Waste Management Plan (HWMP) template. This plan is not an exhaustive inventory of all hazardous waste (HW) requirements and practices. Where applicable, external resources, including Air Force Instructions (AFIs); AF Playbooks; federal, state, local and Final Governing

Standards (FGS); and permit requirements, as applicable, are referenced.

Each section of this HWMP plan begins with standardized, AF-wide “common text” language that addresses AF and Department of Defense (DoD) policy and federal requirements. This common text language is restricted from editing to ensure that it remains standard throughout all plans. The common text language is maintained and updated by the designated Office of Primary Responsibility (OPR) with assistance from the Office of Collateral Responsibility (OCR), as appropriate. Immediately following the

AF-wide common text sections, are Installation sections. The Installation sections contain installation-specific content to address state, local and installation-specific requirements. Installation sections are unrestricted and are maintained and updated by AF environmental Installation Support Teams (ISTs) and/or installation personnel.

This document is optimized to be accessed and viewed electronically. The eDASH website at https://cs1.eis.af.mil/sites/edash/ is the primary communication tool for AF EMPs.

https://cs1.eis.af.mil/sites/edash/

TABLE OF CONTENTS

DOCUMENT CONTROL

1.0 OVERVIEW AND SCOPE

2.0 INSTALLATION PROFILE

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

4.0 GENERAL ROLES AND RESPONSIBILITIES

5.0 TRAINING

6.0 RECORDKEEPING AND REPORTING

7.0 PROCEDURES

7.1 Waste Inventory

7.2 Waste Identification

7.3 Container Management

7.4. Labeling and Marking

7.5 Accumulation Area Management

7.6 Transportation

7.7 Turn In/Disposal

7.8 Inspection

7.9 Waste Minimization

7.10 Preparedness and Prevention

7.11 Waste Specific Procedures

8.0 REFERENCES

9.0 ACRONYMS

10.0 DEFINITIONS

11.0 INSTALLATION-SPECIFIC CONTENT

APPENDICES

Appendix A – Waste Analysis Plan

Appendix B – Emergency Reporting and Information Numbers

Appendix C – File Locations

Appendix D – Accumulation Point Inspection Checklist

Appendix E - Accumulation Site Checklist

Appendix F – Hazardous Waste Marking

Appendix G – Guidelines for Incompatible Materials

DOCUMENT CONTROL

Record of Updates – The HWMP is updated as changes to waste generation and management practices occur, including those driven by changes in applicable regulations.

Record of Updates

Change No. Nature of Change Date of Change Approved By:

4 Annual Review 4/15/2015 DSurber

5 Annual Review 8/26/2016 DSurber

6 Annual Review 10/2/2017 DSurber

7 Annual Review 9/24/2018 DSurber

Record of Annual Review – In accordance with (IAW) AFI 32-7042, Waste Management, this plan is reviewed annually, updated as appropriate, and approved by the Environmental Safety and Occupational

Health Council (ESOHC). Formatting and administrative changes do not require ESOHC review.

Record of ESOHC Annual Review

Review Date Review Participants Notes/Remarks Result in Plan

Update? (Yes or No)

5/19/2015 325 FW Plans Office N/A Yes

10/25/2016 325 FW Plans Office, ESOHC

N/A Yes

10/24/2017 325 FW Plans Office, ESOHC

N/A Yes

10/30/2018 325 FW Plans Office, ESOHC

N/A Yes

Change 7, 24 Sep. 2018

1.0 OVERVIEW AND SCOPE

This HWMP contains procedures for management of HW. In lieu of federal, state or FGS requirements, AFI 32-7042, Waste Management, acts as the main driver for the HWMP. The HW Playbook serves as supplemental guidance to this plan.

Installation Supplement – Overview and Scope

Applicability to Tyndall AFB

The plan covers the control and management of hazardous wastes from the point where they are generated on Tyndall, 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 and the State of Florida’s Department of Environmental Protection regulations contained in Florida Statute Chapter 62-730. Information in support of this plan was obtained through conversation with Tyndall AFB personnel, initial accumulation point (IAP) managers, Civil Engineer/Environmental personnel (CEIE), 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.

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.

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.

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

Personnel training/requirements as stipulated in 40 CFR 262.34 (a) (5) and 265.16 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 Emergency

Planning and Response Plan (HMEPRP) is also addressed to supply shop personnel with necessary emergency procedures relative to their workplace.

Records created as a result of processes prescribed in this plan will be 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).

2.0 INSTALLATION PROFILE

Installation Profile

Scope of Plan The individual base operational units (generating activities) are accountable for conducting their activities in accordance with this plan.

Office of Primary Responsibility

(OPR)

325 CES/CEIE has overall responsibility for implementing the HW management program and is the lead organization for monitoring compliance with applicable federal, state and local regulations

HW Program Manager Dan L. Surber (850) 283.4486

Alternate HW Program Manager HWAS Manager: Preston Lewis (850) 283.4780

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

Refer to Appendix B for additional contact information

Waste registration numbers EPA ID Number FL1570024124

HW generator status Large quantity generator (LQG)

Universal waste handler status Small Quantity Handler of Universal Waste

Permitted HW operations N/A

Federal or FGS regulatory references 40 CFR 260-271

State and local regulatory agencies Florida Department of Environmental Protection (DEP)

State and local regulatory references 62-730 F.A.C

Approved HW disposal contractors DLS-DS Contractor: Willow Environmental

HW accumulation sites Building 6011

HW accumulation time limits 90 Day

HW generator reporting frequency Biennial Reporting

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

The AF environmental program adheres to the Environmental Management System (EMS) framework and its Plan, Do, Check, Act cycle for ensuring mission success. Executive Order (EO) 13693, Planning for Federal Sustainability in the Next Decade, U.S. Department of Defense Instruction (DoDI) 4715.17, Environmental Management Systems, AFI 32-7001, Environmental Management, and international standard, ISO 14001:2004, provide guidance on how environmental programs should be established, implemented, and maintained to operate under the EMS framework.

The HW management program employs EMS-based processes to achieve compliance with all legal obligations and current policy drivers, effectively managing associated risks, and installing a culture of continuous improvement. The HWMP serves as an administrative operational control that defines compliance-related activities and processes.

4.0 GENERAL ROLES AND RESPONSIBILITIES

The major roles/organizations involved in supporting the HW program include:

Wing/Installation Commander

ESOHC

HW Manager/Alternate

Shop/HW Generator Personnel

Initial Accumulation Point (IAP) and Hazardous Waste Accumulation Site (HWAS)

Supervisors/Managers

Unit Commanders

Unit Environmental Coordinators (UECs), see AFI 32-7001 for role description

Contracting Officer

Defense Logistics Agency Disposition Services

Tenant Organizations

AFCEC

Detailed information about typical responsibilities for these and other roles is available in the HW

Playbook. Additional HW management-related roles and responsibilities are described throughout this plan and in referenced documents.

Installation Supplement – General Roles and Responsibilities

Overview

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).

The following organizations are tasked under this plan: 325th Fighter Wing Commander, (ESOHC

Chairperson); 325th Civil Engineer Squadron; 325th Logistics Readiness Squadron (Materiel

Management, Fuels Management, and Vehicle Management); 325th Medical Group; 325th Maintenance

Group (AMXS, MXS, DS2, AFETS); 325th Communications Squadron;

325th Force Support Squadron; Air Force Civil Engineering Center (AFCEC); AIR 1ST. Organizations that have specific responsibilities for the hazardous waste management program as well as those organizations that handle hazardous waste are described below.

Section B Specific Responsibilities

325th Fighter Wing Commander (325 FW/CC)

Serves as ESOHC Chairperson.

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).

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.

Signs installation hazardous waste permit applications.

Sign, or delegate in writing the authority to sign, HW manifests

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

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

Ensure that employees handling HW have HW responsibilities reflected in their job descriptions.

Ensure that a HW minimization program is in place to reduce the volume and toxicity of waste generated.

Ensure appropriate use of the standardized Air Force HW system, EESOH-MIS, to include tracking of waste generation from shop processes, transfer to central accumulation storage, cost, and turn-in for disposal.

325th Civil Engineer Squadron (325 CES/CC)

Civil Engineer (CE) has the overall responsibility to ensure installation complies with established hazardous waste regulations and procedures.

o Oversee proper programming and recordkeeping procedures.

o Act as the liaison office for environmental compliance issues with regulatory agencies, IAW applicable policy.

o Work with AFCEC/CZ to prepare and modify required permits in coordination with the base legal office.

o Implement procedures (HW Plan, etc.) to ensure generators maintain up-to-date waste stream information and profiles, to include sustainment of the EESOH-MIS.

Reviews and signs the hazardous waste management plan record of annual review as delegated from ESOHC.

Ensures the hazardous waste management training is provided annually.

Ensure the proper disposal of all wastes from the installation.

Maintain all SW and HW related records in an approved environmental reporting system and

IAW retention times prescribed by the Air Force RDS. For HW, the approved environmental reporting system is EESOH-MIS.

325th Civil Engineer Squadron / Environmental Element (325 CES/CEIE)

Environmental Manager for the base hazardous waste program.

Updates the hazardous waste management plan.

Conducts or coordinates hazardous waste management training for all base personnel who generate or manage hazardous waste.

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

Performs hazardous waste management compliance surveys of Tyndall AFB properties.

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

Prepares and submits reports to the EPA and Florida DEP.

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

Prepares permit applications as required. Coordinates permit applications with 325 FW/CV.

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:

o Facility layout plan.

o Location of each facility that generates hazardous waste and the quantity of wastes at each

IAP.

o Records and results of waste analysis and trial tests.

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

o Records and results of inspections.

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

DEP.

Maintains routine liaison with AFCEC Eglin Installation Support Team (EIST), EPA Region IV, and Florida DEP in regard to hazardous waste inspections, rule interpretation, and problem resolution.

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.

Ensures all hazardous waste is accurately weighed for disposal actions.

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

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

Inspects treatment, storage and disposal facilities (TSDFs) where waste is taken by disposal contractor other than DLA Disposition Services.

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

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 CEIE on analysis, and provide results of analysis to CEIE in support of hazardous waste determination.

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

Manager.

Reviews new hazardous material authorization requests via AF Form 3952 or the automated electronic program.

Specifies 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 can be implemented).

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

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

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.

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

AFNORTH-Tyndall Command Center, and to the Public Affairs duty section where an information center may be established.

o 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 Incident Commander.

Commanders/ Program Managers of Generating Activities

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

Provides safe equipment and locations for IAPs and accumulation sites. Coordinate each location with Environmental Manager, Ground Safety, Fire and Emergency Services Flight, and

Bioenvironmental Engineering Flight (BEF), 325 AMDS/SGPB.

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

Appoints an IAP manager for shops that generate hazardous waste. The IAP manager retains overall responsibility for the management of the IAP. For military supervisors, management duties may be delegated by the shop supervisor.

IAP manager maintains a Hazardous Waste Compliance Folder.

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

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.

Hazardous Waste Accumulation Site Manager

Assumes overall responsibility for management of the hazardous waste accumulation site

(HWAS) and IAPs under their responsibility.

Ensures accumulation sites have appropriate warning signs.

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

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

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

Ensures that hazardous wastes are collected, weighed, and stored in approved containers

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

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

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

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

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

o Waste description o Accumulation start date (the date that the first amount of hazardous waste was placed into the container at accumulation sites) o The Tyndall AFB assigned container number

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

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

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

Maintains all hazardous waste documentation regarding the hazardous waste stream inventory in

EESOH-MIS.

Hazardous Waste IAP Manager.

Ensures the hazardous waste procedures outlined in Section 7 of this plan are executed, as applicable.

Assumes overall responsibility for management of the hazardous waste IAPs under their responsibility.

Ensures IAPs have appropriate warning signs.

Performs and documents inspections of the IAPs. Inspections must be performed monthly.

Ensures that hazardous wastes are collected and stored in containers that have been issued unique numbers from EESOH-MIS.

Ensures that hazardous wastes are in appropriate containers capable of being loaded and transported.

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

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

Ensures that all hazardous waste is placed in accumulation containers that are listed on the shop’s

Hazardous Waste Site Waste Stream Summary Report generated from EESOH-MIS.

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).

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

Defense Logistics Agency- Disposition Services (DLS-DS).

Ensure hazardous waste is disposed in accordance with state and federal regulation. Ensure TSDFs are in compliance.

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.

5.0 TRAINING

HW awareness training is provided to satisfy regulatory requirements and needs. All personnel whose work involves HW, and their immediate supervisors, must successfully complete HW training appropriate to their job responsibilities. Until the employee has received the appropriate HW training, the employee may only handle HW under the supervision of a trained individual. HW training is provided by authorized personnel. Training records are maintained IAW the Recordkeeping and Reporting section of this plan.

Installation Supplement – Training

Section A--Hazardous Waste Training Requirements

Personnel for Which Training is Mandatory

Tyndall AFB personnel who perform any of the following tasks must receive hazardous waste training according to the category which that task is assigned. Each hazardous waste employee’s supervisor must complete the same training as their employee. The categories for hazardous waste management are

Hazardous Waste Generators, IAP Managers, and HWAS Managers

Hazardous Waste Generators are personnel who:

o Decide which wastes are hazardous waste o Add/Remove hazardous waste into accumulation containers at IAPs o Add/Remove universal waste from accumulation containers o Respond to spills, fires, or explosions, involving hazardous waste

IAP Managers are personnel who:

o Assigned to perform the duties is section 7 o Transport hazardous waste to HWAS o Respond to spills, fires, or explosions, involving hazardous waste o Appointed Unit Environmental Coordinators for organizations with IAPs

HWAS Managers are personnel who:

o Complete hazardous waste manifests, annual reports, or exception reports o Inspect HWAS o Manage HWAS

Training Frequency

The required training must be successfully completed by all of the personnel described above. For new personnel, training must be successfully completed prior to their assignment to a position involving the handling or management of hazardous waste. Until that time, untrained personnel must not perform any tasks involving hazardous waste management unless they are supervised by trained personnel. Personnel requiring hazardous waste training are required to take an annual refresher course.

Section B--Training Scope

Training Components

There are three general components to the training required by RCRA in 40 CFR 265.16. Personnel must be trained: 1) how to perform their duties in a way that ensures Tyndall AFB compliance with hazardous waste regulations; 2) hazardous waste management procedures, including contingency plan implementation; and 3) how to respond to emergencies involving hazardous waste.

Air Force Hazardous Waste Management Training Program

Tyndall AFB uses the The Environmental Awareness Course Hub (TEACH) supported by Air

Force Civil Engineering Center located on eDASH to train applicable base personnel on the general requirements of the hazardous waste regulations. Tyndall AFB's specific procedures for waste determination, accumulation, transportation, and turn-in are incorporated into an Initial IAP

Manager class. Newly appointed IAP, HWAS Managers, UECs must complete the initial training in the next monthly class offered by CEIE. IAP and HWAS Managers annual refresher training will be accomplished by taking hazardous waste awareness training on TEACH. If any CFR findings are identified during the Internal ECAMP or External UEI inspections, the IAP Manager must repeat the Initial IAP Manager Class.

Generators of hazardous waste are personnel who meet any of the criteria in section 6.1.1.

Generators are exposed to hazardous waste but are not responsible to manage the IAP. Personnel who generate hazardous waste will complete the hazardous waste awareness module in TEACH.

Also, generators need to be trained by their shop’s IAP manager, or the shop supervisor on site specific procedures not addressed in TEACH which include the shop specific Hazardous Waste

Contingency Plan.

Required Records

Training records are required to document that all appropriate personnel have successfully completed their required training. The following records should be maintained by the Environmental Manager:

The job title for each position at the installation related to hazardous waste management and the name of the employee filling each job.

A written job description for each position related to hazardous waste management. For the purposes of RCRA training records, the job description need only describe the job as it relates to the management of hazardous waste and must include the requisite skills, education, or other qualifications, and the duties of facility personnel assigned to each position.

A written description of the type and amount of both introductory and continuing training that will be given to each person filling a position related to management of hazardous waste.

Records documenting the training or job experience required to meet the training requirements have been provided to, and completed by, base personnel. These records must be kept for current employees as long as they work at the base installation and for an additional 3 years after the date they leave the base (or stop working at a position related to hazardous waste management). Training records may accompany personnel transferred to another installation.

6.0 RECORDKEEPING AND REPORTING

Recordkeeping

The installation complies with the following U.S. Federal HW recordkeeping requirements.

Summary of HW Recordkeeping Requirements

Record* Retention Time** Citation

HW determination documentation

3 years from the date that the waste was last sent to a TSDF

40 CFR 262.40

HW Biennial/Annual Report 3 years from the due date of the report 40 CFR 262.41

HW manifest 3 years from the day the waste was accepted by the initial transporter

40 CFR 262.40

HWAS inspection logs 3 years from the date the inspection was conducted

40 CFR 262.34

40 CFR 265.15 (d)

40 CFR 265.174

Exception reports 3 years from the due date of the report 40 CFR 262.42

Land restricted waste determination

3 years from date the determination was required to be conducted. If not required, 3 years from the date the waste was last sent to a TSDF

40 CFR 268.7

Land restriction notice and certification

3 years from the date the waste was last sent to a TSDF

40 CFR 268.7

Notification of intent to export waste

3 years from the date the HW was accepted by the initial transporter

40 CFR 262.53

EPA acknowledgement of consent (for exports)

3 years from the date the HW was accepted by the initial transporter

40 CFR 262.51

40 CFR 262.53

Waste export confirmation of delivery

3 years from the date the HW was accepted by the initial transporter

40 CFR 262.54

Annual report (required of primary exporters of HW)

3 years from the date the HW was accepted by the initial transporter

40 CFR 262.56

Employee training records

(including appointment letters for key HW personnel)

Current personnel: until closure of the site;

Former personnel: 3 years from date the individual last worked there

40 CFR 262.34

40 CFR 264.16

40 CFR 265.16

*Permitted Treatment, Storage and Disposal Facilities (TSDF) comply with recordkeeping requirements established in their HW permit.

**Retention Time may be extended during the course of any unresolved enforcement action or as requested by the U.S. Environmental Protection Agency (EPA). The AF, through the Air Force Records Information

Management System (AFRIMS), requires that HW-related reports, documents, studies, HW manifests, and disposal records (including contracts) are destroyed 50 years from the date of the record.

Reporting

The HW Manager, and other designated personnel, generate needed reports from EESOH-MIS.

Enforcement actions, spills and inspections are reported via the Enforcement Actions, Spills, and

Inspections (EASI) database.

Installation Supplement – Recordkeeping and Reporting

Record Keeping

RCRA requires the maintenance of certain records on base. Disposition of records shall be in accordance with Air Force Manual 37-139. The Environmental Manager shall maintain or know the whereabouts of the files identified in the table and shall make them available to appropriate

State of Florida and federal inspectors upon request.

The Environmental Manager will also maintain copies of hazardous waste profile sheets and list all hazardous waste transfers to the Accumulation Site for at least 5 years after disposing of the waste streams covered by the reports. The Environmental Manager will also maintain an updated copy of this Hazardous Waste Management Plan and accompanying hazardous waste stream inventory and waste analysis plan. Appendix C identifies the location of files containing hazardous waste determinations, manifests, and inspection logs.

Reporting

Biennial Report

The State requires biennial reports from hazardous waste generators each year covering hazardous waste activity over the previous calendar year.

Emergency Reports

Releases above the RQ (Reportable Quantity) of hazardous waste, hazardous substances, and hazardous materials onto the land or into the waters of the state must be immediately reported to the Florida

Department of Environmental Protection (DEP) at (850) 872-7650. See the Tyndall Air Force Base

HMEPRP for additional requirements regarding the reporting of hazardous waste spills, releases, fires, or explosions.

Incident Report

In the event that the contingency portion of the HMEPRP is implemented, incidents must be reported in accordance with Tyndall AFB HMEPRP. If requested by EPA or otherwise required by regulatory requirements, Tyndall AFB must submit reports pursuant to 40 CFR 264, Subparts F and K through N.

7.0 PROCEDURES

This section contains procedures for managing HW from identification, accumulation, offsite transportation and disposal. The HW Manager ensures that appropriate procedures are properly communicated and followed by all necessary personnel.

7.1 Waste Inventory

A current waste inventory can be generated within EESOH-MIS using the Ad-Hoc Reporting Tool or by completing the following steps:

Log into EESOH-MIS; Select the “Reporting” option; Select “Hazardous Waste” to generate the

Waste Site Waste Stream Summary Report

Installation Supplement – Waste Inventory

Tyndall AFB maintains a hazardous waste stream inventory (HWSI) for every hazardous waste stream generated on base. CEIE 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). Each shops HWSI is depicted as a list from EESOH-

MIS that combines an instance of Tyndall’s generic waste streams combined with the storage location that is near the point of generation of the HW. This list is generated from EESOH-MIS as a report titled

“Waste Site Waste Stream Summary Report.” Tyndall AFB will not handle, store, transport, dispose of or inventory non DoD owned hazardous wastes or materials except as authorized.

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

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

7.2 Waste Identification

The HW Manager determines the nature of waste based on a detailed qualitative analysis of the regulated waste generating process, associated Safety Data Sheet (SDS) information, and coordination with generating activity personnel involved in the use of hazardous materials. If uncertainties about a waste stream exist, the HW Manager pursues waste stream sampling and analysis IAW the Waste Analysis Plan

(WAP).

The WAP details the wastes that have been evaluated and analyzed, a description of the testing and analytical methods used, the HW sampling methods used, the location of samples taken for analysis and frequency, sample documentation, sample quality assurance and quality control procedures, and sample request procedures.

Generator knowledge and the results of the WAP are used to minimize waste re-characterizations to those instances where a process change has occurred or the waste stream is highly variable.

Installation Supplement – Waste Identification

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 Appendix A).

Hazardous wastes will be characterized on the DRMS Form 1930. With input from generating activities, the hazardous waste program manager is responsible for quantifying all hazardous wastes for the hazardous waste stream inventory.

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

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

Recycled, not subject to the generator waste determination requirements of 40 CFR § 262.11

(e.g., used oil that is burned for energy recovery, and scrap metal which is recycled) (40 CFR

261.6)

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

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.

7.3 Container Management

Container management procedures are as follows:

Containers storing HW must be in good condition and meet permit, transportation and other applicable requirements. “Good condition” means there should be no severe rusting, no sharp-edged creases or dents, no bulging heads and no severe structural defects.

Ensure that the waste material will not react with the container itself.

Use plastic or plastic-lined steel drums to safely store corrosive wastes.

Immediately transfer the contents of a leaking container to another container or over pack into a salvage drum.

Containers with free liquid or drum contents on top must be cleaned or over packed in the case of a leak.

Containers must remain closed at all times except when adding or removing waste. Adequate headspace must be maintained at all times when filling a container to account for content expansion.

Installation Supplement – Container Management

Containers used to store hazardous waste must be kept closed at all times, except when waste is being added to or removed from the container. In general, a container is closed if its original closures, such as bung caps or drum heads, are secured to the container. During storage, an open-head 55-gallon drum should have its drum head in place with the retaining ring properly secured with the appropriate nut and bolt. The use of a “Quick-close” ring or other means of sealing the container are approved so long as, vapors are contained, and the material inside will not be released if the drum is tipped over.

Containers must not be stored or handled in a manner, which may cause them to rupture or leak. The following precautions should be taken at accumulation points to prevent container ruptures and leaks:

Containers must not be overfilled; fill to 90% of capacity.

Containers must be maintained in good condition.

Containers must be protected from freezing during cold weather. Many materials go through a freeze/thaw cycle during changing weather conditions.

Containers of liquid, flammable hazardous waste must be grounded. Grounding will prevent build up of static electricity during pumping or pouring which may ignite flammable vapors. When transferring flammable liquids between containers, use a bonding wire to connect the container to prevent the build up of static.

Drums and other containers must be handled and transported with equipment designed for the task. Contact CEIE at 3-4780 if you need assistance on how to safely transport hazardous waste.

Secure containers to pallets before moving pallets. Use drum carts designed for the types of containers used by your organization to reduce the likelihood of dropping a container during handling. Never balance drums on the forks of a forklift or tow motor.

Drums must not be stacked more than two high. Labeling must be on side of drum if stacked.

Drums containing flammable liquids will not be stacked.

Containers shall be stored in an area which is well away from or protected from damage due to the movement of vehicles such as trucks, forklifts, POVs etc.

Where appropriate absorbent material and spill control supplies must be maintained nearby.

If unsure whether a waste to be disposed of or placed in a container is compatible with the waste in the container itself, contact the Environmental Manager before placing waste in the container.

Incompatible wastes, or incompatible wastes and materials must not be placed in the same container. In addition, hazardous waste must not be placed in an unwashed container that previously held an incompatible waste or material.

7.4. Labeling and Marking

Containers used for the accumulation and transportation of HW are properly labeled IAW applicable laws and regulations.

Each container is properly marked and labeled from initial accumulation area to HWAS to disposal/turn-in. The waste-generating activity ensures that the label on each waste container is clearly visible for inspection. During accumulation at an IAP, HW containers are marked with the following:

o The words “Hazardous Waste” o A description of the contents of the container o The hazards associated with the waste

Once an IAP accumulates more than 55 gallons of HW (or 1 quart of acute HW), the IAP site manager marks the container with the date on which 55 gallons (or 1 quart of acute HW) is exceeded, and removes the excess of 55 gallons (or 1 quart of acute HW) within three days.

HW containers 110 gallons or less that are shipped offsite are marked with the following:

“Hazardous Waste – Federal Law prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency”

Generator’s name and address

Generator’s EPA Identification Number

Manifest tracking

These markings are:

Durable

In English, and/or appropriate host nation language

Printed on or affixed to the surface of a package or on a label, tag or sign displayed on a background of sharply contrasting color

Unobscured by labels or other attachments

Located away from any other markings that might substantially reduce visibility or effectiveness

UW, or a container in which a UW is contained, is labeled and marked clearly with the date the material became a waste and the name of the waste, as described below:

UW batteries must be labeled with any one of the following phrases: “Universal Waste-

Battery(ies),” or “Waste Battery(ies),” or “Used Battery(ies)

UW thermostats must be labeled with any of the following phrases: “Universal Waste-Mercury

Thermostat(s),” “Waste Mercury Thermostat(s),” or “Used Mercury Thermostat(s)

UW pesticides must be labeled with any of the following phrases: “Universal Waste-Pesticide(s)” or “Waste-Pesticide(s)

UW lamps must be labeled with one of the following phrases: “Universal Waste—Lamp(s),” or

“Waste Lamp(s),” or “Used Lamp(s)

Installation Supplement – Labeling and Marking

Hazardous Waste Accumulation Site Container Marking.

Container marking during hazardous waste accumulation shall consist of the following information:

The words “HAZARDOUS WASTE” or

Waste description, Hazardous Waste Code (if known), and principal constituents

Accumulation start date

Labeling

The responsibility for labeling for shipment falls with the hazardous waste disposal contractor representative. However, the hazardous waste site accumulation manager must verify that all handling and labeling of containers is in accordance with regulatory requirements.

Additional container marking prior to transferring the waste off-base shall consist of the following information required by EPA and DOT. All marks must be durable (i.e. using permanent marker), in English, and printed on or affixed to the surface of a package or on a label, tag or sign, displayed on a background of sharply contrasting color, unobscured by labels or other attachments and located away from any other marking, such as advertising, that might substantially reduce its visibility or effectiveness. Each container (also referred to as package) shall be marked with the following information:

Items under Container Marking above shall remain on the container

The EPA Generator Number

The proper shipping name and the corresponding UN or NA identification number must be marked on each package of hazardous waste. The proper shipping name is on the hazardous waste profile sheets.

Packages containing hazardous substances must be marked with the letters "RQ" and the appropriate quantity in association with the proper shipping name. If the proper shipping name does not identify the hazardous substance by name, also mark the package with one of the following:

o The name of the hazardous substance as shown in the Appendix to 49 CFR 172.101, DOT

Hazardous Materials Table;

o The EPA hazardous waste number; or o For characteristic hazardous wastes, the word "ignitability," "corrosivity," "reactivity,"

"toxicity," or the corresponding "D" hazardous waste number.

When shipping overpacks or other packages with inside packaging containing liquid hazardous wastes, mark the outside package with an arrow symbol indicating "This Way Up."

Wastes and materials which are a poison inhalation hazard must be marked "Poison - Inhalation

Hazard".

The EPA hazard warning must be marked on each container of 110 gallons or less. The EPA hazard warning (preprinted labels can be purchased commercially) contains the wording shown in

Appendix F.

Containers shall be labeled in accordance with the following requirements prior to shipment off-site.

o DOT hazardous materials warning labels which represent the hazard of the material being shipped must be affixed to containers before being offered for transportation.

o Some hazardous material descriptions have more than one hazard class listed in the DOT

Hazardous Materials Table. A waste may exhibit one or more of these hazard classes. If the container being shipped contains waste exhibiting only one of the hazard classes listed in the table, the appropriate label should be affixed to the container. If the container contains waste meeting the definition of more than one hazard class, multiple labels are required. Multiple labels must be located next to one another.

IAP Container Marking

Container marking during waste accumulation shall consist of a EESOH-MIS generated hazardous waste label with a waste description initiated in EESOH-MIS by CEIE. The use of commercially available hazardous waste label may be preapproved by CEIE to allow compliance with marking requirements until an EESOH-MIS is available.

7.5 Accumulation Area Management

Accumulation area management procedures are as follows:

o IAPs are used to accumulate up to 55 gallons of HW or 1 quart of acute HW.

o If HW or acute HW are accumulated in excess of these amounts, the generator marks the container with the date the amount was exceeded and transfers the container to a HWAS or TSDF within 3 days.

o HW is accumulated in a HWAS for up to 90 days for a LQG, or 180 days (270 days if waste has to be shipped over 200 miles) for a SQG.

o HWASs comply with all applicable federal, state, local and FGS accumulation requirements, including proper waste segregation.

Installation Supplement – Accumulation Area Management

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) within three days. The areas designated as hazardous waste accumulation points are identified in the Tyndall IAP Summary Report located in the Hazardous Waste

Module of the EESOH-MIS and available upon request. On Tyndall, accumulation of hazardous waste is an internally permitted process. If any change occurs in either the make-up of the hazardous waste being generated or the process of generation the Hazardous Waste Storage Permit (HWSP) must be re-accomplished to include the location of the point. The HWSP approval process is outlined by the minutes of the Hazardous Material Management Process Team meetings.

Accumulation Site Operational Requirements

A hazardous waste accumulation site must comply with the requirements for siting, physical construction, operations, marking, labeling, inspections, and maintaining a container log. If an additional accumulation site is required, a location shall be selected, in coordination with the Environmental Manager, which minimizes the threat of the waste to human health or the environment in the event of a release of the hazardous waste.

Receiving of Hazardous Waste at Accumulation Sites

Hazardous waste is received and managed at Building 6011 as follows:

The accumulation site manager must ensure waste is properly labeled.

Each container is unloaded and weighed. The weight in pounds is written on top of each container. Containers will be marked per Installation Supplement – Labeling and Marking.

The container number is a unique number assigned to each container. The numbering system will be generated at Building 6011.

Lids and bungs are rechecked before storage.

Appropriate hazardous waste information is entered in the EESOH-MIS database.

A turn-in document is generated in the EESOH-MIS database.

Storage of Hazardous Waste at Accumulation Sites

Hazardous wastes stored in Building 6011 are managed as follow:

After receiving, transfer hazardous waste to a storage area containing compatible hazardous

Record the waste on the Accumulation Site database.

The hazardous waste in this facility can be stored no longer than 90 days.

Containers used to store hazardous waste must be kept closed at all times, except when waste is actually being added to or removed from the container. In general, a container is closed if its original closures, such as bung caps or drum heads, are secured to the container.

Containers must not be stored or handled in a manner which may cause them to rupture or leak.

Containers of top of must not be overfilled; fill to 90% of capacity, within 4 55-gallon drums.

Grounding:

o Containers of Flammable and…