JB_CHS_Hazardous_Waste_Management_Plan.pdf

Joint Base Charleston Hazardous Waste Management Plan August 2014 (Rev 1 December 2015)

UNCLASSIFIED

Hazardous Waste Management Plan Joint Base Charleston, SC

August 2014 (Rev 1, December 2015)

OPR: 628 CES/CEIE

210 W. Stewart Ave Joint Base Charleston, SC 29404

ENVIRONMENTAL, SAFETY, AND OCCUPATIONAL HEALTH COUNCIL (ESOHC) APPROVAL

Full approval of this Joint Base Charleston Hazardous Waste Management Plan (HWMP) is recognized by the Environmental, Safety and Occupational Health Council (ESOHC) and the Joint Base Commander, who has the necessary authority to commit the necessary resources to implement the plan. The plan will be implemented as herein described.

This plan supersedes all previous versions at the Air Base and Weapons Station. In accordance with Air Force Instruction (AFI) 32‐7042, the ESOHC will perform annual review and approval of this plan.

The office of primary responsibility for this plan is the Environmental Element of the Civil Engineer Squadron Installation Management Flight, 628 CES/CEIE, (843) 963‐1472, DSN 673‐1472.

ROBERT K. LYMAN, Colonel, USAF Date Commander, 628th Air Base Wing

Record of Reviews

Review Date Reviewer’s Name Reviewer Organization Comments

August 2014 Lewis, Barry 628 CES/CEIE Complete Revision

Rev 1, December

Lewis, Barry

628 CES/CEIE

Added EESOH‐MIS responsibilities and other minor administrative changes.

Emergency Reporting Information

Report On‐Base Emergencies to Base Fire Department:

Fires, explosions, or spills 911 (JB CHS‐A on base) 8 4 3 ‐ 963‐8400 (off base, cellular) Fires, explosions, or spills 911 (JB CHS‐W on base) 8 4 3 ‐ 963‐8400 (off base, cellular)

Emergency Medical Service: 911

Emergency Assistance and Information:

JB CHS‐A On‐Base (843‐963‐) JB CHS‐W On‐Base (843‐963‐) Hazardous Waste Program Manager x2727 Hazardous Waste Program Manager x1470 Wing Safety x5603 Wing Safety x7569 Public Affairs x5608 Contracting Officer x5157 Staff Judge Advocate x5502

HQ Air Mobility Command:

AMC Environmental Release Hotline

US EPA:

Hazardous Waste Information Hotline (800) 424‐9346 EPA Region IV (404) 562‐8700

Federal, State, and Local Release Reporting:

National Response Center (800) 424‐8802 South Carolina Emergency Response Team (803) 734‐0425 South Carolina DHEC, Trident Office (843) 740‐1590 (Daytime Hours) SCDHEC Emergency Response (888) 481‐0125 (24 Hours) SC Emergency Operations Center 1‐800‐811‐8045

County Emergency Preparedness Divisions (Daytime Hours):

Charleston County (843) 202‐7400 Berkeley County (843) 723‐3800

US Coast Guard Regional Response Team:

(843) 720‐7733

Executive Summary

1. PURPOSE

a. This Hazardous Waste Management Plan (HWMP) details the approach for managing hazardous waste (HW) on Joint Base Charleston and its remote operating locations. The plan references federal, state, and local regulations and Air Force directives that establish definitive compliance requirements. Federal Facilities are not exempt from the requirements of the Resource Conservation and Recovery Act (RCRA) as implemented by the US Environmental Protection Agency (EPA) and enforced by the South Carolina Department of Health and Environmental Control (SCDHEC). This plan outlines the Hazardous Waste Management Program and subsequent plans to control and manage hazardous wastes (HW) from the point of generation through final disposal and to assure that HW do not pose a threat to human health or the environment.

b. The purpose of this plan is to provide base personnel with a comprehensive reference relating to the policies and procedures to be implemented on Joint Base Charleston and its remote operating locations to ensure hazardous waste is handled and managed in a manner that is responsive to mission requirements, protective of personnel safety, cost effective, and compliant with applicable regulations. While many specific procedures are identified, organizations may supplement this Hazardous Waste Management Plan with more detailed instructions and checklists to facilitate shop‐level operations as long as these instructions do not conflict with applicable federal and state HW regulations and this plan.

2. SUMMARY OF CHANGES

a. This is a complete revision of any and all previous Hazardous Waste Management Plans (CHARLESTON AIR FORCE BASE INSTRUCTION 32‐7042, 9 APRIL 2004; Incorporating Change 1, 19 December 2006, and WPNSTACHASNINST 5090.1E dated 23 Jun 2009), and has been extensively updated to reflect changes affecting the management of hazardous waste as reflected in federal, state and county regulations; Department of Defense and Air Force instructions and guidance memoranda; and procedural improvements based on accumulated experience to enhance management effectiveness and efficiency.

b. This plan also reflects changes in the organizational structure, unit designations and procedural modifications that have occurred as a result of Joint Basing, Civil Engineering Transformation (CET), and other applicable changes.

c. Additional changes to this plan include incorporation of the Enterprise Environmental, Safety, and Occupational Health – Management Information System (EESOH‐MIS) requirements. EESOH‐ MIS will be used to track waste generation from shop processes, transfers of wastes to the Part B Permitted Storage Facilities, disposal costs, and turn‐in’s to DLA for off‐site disposal as required by AFI 32‐7042 Section 2.7.1.8 –latest version.

3. APPLICABILITY

a. This plan is applicable to all Department of Defense (DOD) entities, other federal agencies, and supporting government contractors and their subcontractors that generate hazardous waste on Joint Base Charleston (Air Base and Weapons Station), and/or at any of its remote operating locations.

4. IMPLEMENTATION

Compliance with this plan as it relates to the management of hazardous waste is required for all readiness conditions. This Hazardous Waste Management Plan is based on the federal, state, and local regulations and Air Force directives available at the time of preparation, and it is subject to modification as those requirements change. Accordingly, this plan will be reviewed annually—or upon notification of changed requirements—and updated as required.

a. Cognizant government offices must include this plan’s requirements in their requirements packages, solicitations, and contracts entailing the generation of hazardous waste under either the Air Base or Weapons Station Environmental Protection Agency (EPA) identification number or that of any of its remote operating locations.

b. The procedures prescribed in this plan are based on compliance requirements and approved base policies and practices. Policies and procedures from previous Hazardous Waste Management Plans that have not been incorporated into this plan are considered obsolete. Any subsequent local policy direction and/or guidance will be issued by 628 CES/CEIE in the form of policy guidance letters, which will remain in effect until the next update of this plan when they will be either incorporated or rescinded.

Table of Contents Record of Reviews

Emergency Reporting Information

Executive Summary

Abbreviations and Acronyms

References

1. Overview

2. Responsibilities

3. Waste Inventory

4. Waste Analysis Plan

5. HW Management Procedures

6. Reporting Procedures

7. Training Plan

8. Waste Minimization Plan

9. Pollution Prevention Plan

10. Glossary

Attachment 1 ‐ List of HWAS and HWIAP Locations

Attachment 2 – WASTE STREAM CHARACTERIZATION PROCESS DOCUMENT

Attachment 3 – Hazardous Waste Profile Sheet

Attachment 4 – Sample and Analysis Request Form

Attachment 5 – Hazardous Waste Label

Attachment 6 – Non‐RCRA Waste Label

Attachment 7 – Universal Waste Label

Attachment 8 – Hazardous Waste Accumulation Site (90‐Day Site) Weekly Checklist

Attachment 9 – Hazardous Waste Initial Accumulation Point (SAA) Weekly Checklist

Attachment 10 – Hazardous Waste Transfer/ Turn‐In Document

Attachment 11 – Hazardous Waste Transfer/ Turn‐In Document

Attachment 12 – Hazardous Waste Facility Inspection Report

Attachment 13 – Permitted Storage Facility Discrepancy Log

Attachment 14 – Material Pending Analysis (MPA) Label

Attachment 15 – Waste Stream Characterization Process Document For Contractors

Page Intentionally Left Blank

Abbreviations and Acronyms

AF ‐ Air Force AFI ‐ Air Force Instruction AFPD – Air Force Policy Directive AMC – Air Mobility Command CE ‐ Conditionally Exempt CES – Civil Engineering Squadron CFR – Code of Federal Regulations CERCLA ‐ Comprehensive Environmental Response, Compensation, and Liability Act of 1980 DDA ‐ Designated Disposition Authority DDESB ‐ Department of Defense Explosives Safety Board DLA – Defense Logistics Agency DoD – US Department of Defense DOT – US Department of Transportation EOD ‐ Explosive Ordnance Disposal EPCRA – Emergency Planning and Community Right‐to‐Know Act ESOHC ‐ Environment, Safety, and Occupational Health Council ESOHCAMP – Environment, Safety, and Occupational Health Compliance Assessment and Management Program EESOH‐MIS – Enterprise Environmental, Safety, and Occupational Health Management Information System EPA – Environmental Protection Agency ESOHC – Environment, Safety, and Occupational Health Councils FC ‐ Facility Code FP – Flash Point FSC ‐ Federal Supply Class FSTR ‐ Full Spectrum Threat Response HazCom – Hazard Communication HM – Hazardous Material HMIRS – Hazardous Materials Information Resource System HQ ‐ Headquarters HW – Hazardous Waste HWSF ‐ Hazardous Waste Storage Facility HWAS – Hazardous Waste Accumulation Site (same as < 90 day Storage Area) HWC ‐ Hazardous Waste Coordinator HWIAP – Hazardous Waste Initial Accumulation Point (same as SAA) WMP – Hazardous Waste Management Plan HWY – Hazardous Waste Storage Yard IST – Installation Support Team JB CHS – Joint Base Charleston JB CHS‐A – Joint Base Charleston – Air JB CHS‐W – Joint Base Charleston – Weapons LDR ‐ Land Disposal Restrictions LP ‐ Liquid Propane MM ‐ Military Munitions MMR ‐ Military Munitions Response MPA ‐ Material Pending Analysis MRIP – Munitions Rule Implementation Policy MSDS – Material Safety Data Sheet

NA – North American Number NOV – Notice of Violation NR – Non‐RCRA NSN – National Stock Number OB/OD ‐ Open Burning/Open Disposal ORM ‐ Other Regulated Material OSCDR ‐ On‐Scene Commander OSHA – Occupational Health and Safety Administration PA ‐ Public Affairs PCB – Polychlorinated Biphenyl POC ‐ Point of Contact POTW ‐ Publicly‐owned Treatment Works PPE ‐ Personal Protective Equipment PPM – Parts Per Million PSN – Proper Shipping Name QA ‐ Quality Assurance QC ‐ Quality Control RCRA – Resource Conservation and Recovery Act of 1976 RQ – Reportable Quantity SAA – Satellite Accumulation Area SCDHEC – South Carolina Department of Health and Environmental Control SCWSN – South Carolina Waste Stream Number SDS – Safety Data Sheet (formerly MSDS) SERC ‐ State Emergency Response Commission TCLP – Toxicity Characteristic Leaching Procedure TOC – Total Organic Carbon TSDF – Treatment, Storage, and Disposal Facility TSS ‐ Total Suspend Solids UHC ‐ Underlying Hazardous Constituents UN – United Nations Number UTS ‐ Universal Treatment Standards UW – Universal Waste UXO ‐ Unexploded Ordnance VOC ‐ Volatile Organic Compound WAP – Waste Analysis Plan WMM ‐ Waste Military Munitions WPS ‐ Waste Profile Sheet WSCP ‐ Waste Stream Characterization Process WTD – Waste Transfer Document

References

AFI 13‐212, Range Planning and Operations

AFI 32‐3001, Explosive Ordnance Disposal (EOD) Program

AFI 32‐7001, Environmental Management

AFI 32‐7042, Waste Management

AFI 32‐7086, Hazardous Materials Management

AFI 90‐801, Environment, Safety, and Occupational Health Councils

AFI 90‐803, Environmental, Safety, and Occupations Health Compliance Assessment and Management Program

AFPAM 32‐7043, Hazardous Waste Management Guide

AFPD 32‐70, Environmental Quality

Joint Base Charleston – Air RCRA Part B Permit #SC3570024460

Joint Base Charleston – Weapons RCRA Part B and Subpart X Permit #SC8170022620

29 CFR Parts 1900‐1910, Labor

40 CFR Parts 260‐299, Protection of Environment

49 CFR Parts 100‐177, Transportation

42 USC 11001, Emergency Planning and Community Right‐to‐Know Act (EPCRA)

HQ USAF/IL Memo, dated 2 Nov 1998, DoD Policy to Implement the EPA’s Military Munitions Rule AFI 32‐7005, Environmental Protection Committees, Supplement 1, 30 August 1999.

June 2014(Rev 1 December 2015)

1. Overview

a. Purpose: The United States Air Force is committed to proper management of hazardous wastes that are generated on their installations. The primary objective of this document is to provide a management plan that gives hazardous waste program managers the essential tools for effective management. This plan complies with all of the applicable federal, state, DOD, and Air Force regulations. This plan identifies responsibilities, requirements, and procedures for proper identification, labeling, storage, and management of hazardous wastes at Joint Base Charleston.

b. Applicability: On May 19, 1980, the EPA published the Hazardous Waste Management

System rules. Subtitle C of the Solid Waste Disposal Act, by the Resource Conservation and Recovery Act of 1976 (RCRA), as amended, directed the EPA to promulgate regulations to protect human health and the environment from the improper management of hazardous waste. The effective date of these far‐ranging regulations was November 19, 1980. RCRA was again amended in 1984. The amendments required increased management of hazardous waste by all organizations on Joint Base Charleston (JB CHS). As authorized by the EPA, the state of South Carolina has developed a program to implement RCRA within the State. The EPA has delegated RCRA implementation to the State. The procedures of this plan will be used to comply with Federal and State legislation and regulations. Plan r e v i s i o n s 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 noted herein.

c. Scope: The requirements of this plan apply to all departments, supported commands, tenants and contractors performing operations on this facility that generate HW. The 628th Air Base Wing is responsible for ensuring compliance with all RCRA requirements for JB CHS including tenants. The individual base operational units (generators) are accountable for conducting their activities in accordance with this plan. Those base units and tenant activities will provide necessary documentation to the installation commander through the Environmental Protection Committee for permit application, provide the reports required by EPA or the State, and ensure compliance with RCRA regulations and permit requirements at the facility.

1) This plan does not include material or waste management of radioactive materials.

These materials are of special interest and are governed by other regulations.

2) Unserviceable munitions and explosives will be treated as hazardous material and will not be identified as hazardous waste until such time that the decision to discard (dispose) is issued by the disposition authority. EOD Operating Instruction 32‐3005, DOD Policy to Implement the EPA’s Military Munitions Rule (1 July 1998), and R.61‐ 79.266, Subpart M provides information on disposal/treatment of unserviceable/excess munitions.

d. The emergency coordination information is found in the Emergency Reporting

Information section above.

e. References used in developing this plan are found in References section above.

f. Definitions of common terms and abbreviations are located in Section 10 – Glossary.

2. Responsibilities

a. Tasked Organizations: Responsibilities for implementing this plan are distributed throughout base organizations that generate, accumulate, monitor, dispose of, or respond to incidents involving hazardous waste. Base compliance with Federal, State, and local hazardous waste laws and regulations is the responsibility of the 628th Air Base Wing Commander through the base Environment, Safety, and Occupational Health Council (ESOHC). The development, maintenance, and implementation of this plan are products of JB CHS ESOHC action. The following organizations are tasked under this plan:

1) ESOHC (Environment, Safety, and Occupational Health Council) Chairperson

2) 628 CES/CEIE (Environmental Element, Installation Management Flight)

3) 628 ABW/SE (Safety)

4) DLA Disposition Services

5) 628 CES/CED (Explosive Ordnance Disposal Flight)

6) Unit Commanders that Generate Hazardous Waste (including Supported Commands and

Tenants)

7) Hazardous Waste Initial Accumulation Point and Hazardous Waste Site Managers/Crew

Chiefs

8) 628 CES/CEF (JB CHS Fire Department)

b. Specific Responsibilities:

1) ESOHC (Environment, Safety, and Occupational Health Council) Chairperson.

a. Ensures that management of hazardous waste on JB CHS complies with applicable portions of 40 CFR Parts 260‐271 and South Carolina State Hazardous Waste Management Regulations.

b. Ensures the Hazardous Waste Management Plan (HWMP) is reviewed and updated, as necessary, at least annually.

c. Ensures installation hazardous waste permit applications are signed.

d. Ensures installation hazardous waste permits are signed.

2) 628 CES/CEIE (Environmental Element, Installation Management Flight):

a. Manages the base’s hazardous waste program.

b. Updates JB Charleston Hazardous Waste Management Plan.

c. Provides support for Emergency Operations as required per the Installation Emergency Management Plan 10‐2.

d. Conducts or coordinates annual hazardous waste management training for all base personnel who handle or who may be otherwise involved in the management of hazardous waste. Maintain training documentation for a minimum of three years.

e. Responsible for daily management and operation of the Part B Container Storage Facilities.

f. Signs hazardous waste manifests, prepares Hazardous Waste Profiles (Form 1930, Hazardous Waste Profile Sheets), prepares hazardous waste reports, and compliance documentation as required by EPA, state regulatory agency, and Air Force instructions.

g. Disposes of HW offsite though DLA Disposition services – including completing all required paperwork (e.g. annual Hazardous Waste Profile Certifications) for DLA – or contracting to dispose of HW through alternate means.

h. Ensures that MICT Inspections are conducted in accordance with the 628th

Wing approved schedule, and findings are recorded and resolved in accordance with all federal, state, and AF regulations.

i. Prepares and submits reports to the Air Force, EPA and South Carolina Department of Health and Environmental Control (SCDHEC) as required.

j. Develops and coordinates compliance with Closure/Post‐Closure Plans for Permitted and Interim Status Units.

k. Oversees proper closure of all 90 Day Storage Sites and HWIAP (SAAs).

l. Maintains the RCRA Permits and prepare permit applications and modifications as required.

m. 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:

1. Facility layout plan

2. The designation and location of each HWIAP and HWAS site (Attachment 1).

3. Records of waste analysis and profiles

4. Summary reports and details of all incidents that require implementing the contingency plan

5. Records and results of inspections

6. Manifests for all off‐site disposal, including return manifests from receiving facility.

n. Maintains routine liaison and function as the sole POC for external agencies (e.g.

AFCEC, EPA, SCDHEC, etc.) for all communications, regulatory queries, interpretations and agency inspections.

o. Assists waste generating activities in hazardous waste identification, waste management, waste m i ni m i z at i o n, waste recycling, waste storage, and disposal.

p. Develops and updates the JB CHS Waste Stream Inventory (Section 3 – Waste Inventory) and the Waste Analysis Plan (Section 4).

q. Initiates action to pay all annual fees received from outside agencies associated with Hazardous Waste Generation, Storage and Disposal.

r. Coordinates sampling efforts for hazardous waste determination. Ensure samples are sent to SCDHEC approved contract laboratories in accordance with the sampling and analytical requirements specified in EPA Publication SW‐846 and JB CHS Waste Analysis Plan (Section 4).

s. Interprets analytical results to characterize waste and prepares the Hazardous

Waste Profile Sheet (Attachment 3).

t. Programs, budgets and funds disposal of HW for all supported units while ensuring proper disposal for all tenants.

u. Transports HW from the generator (supported units and tenants) to the Part B

Container Storage Facility (JB CHS‐W only).

v. Ensures compliance with all state, federal, and AF regulations for the Subpart X Permitted Northside OB/OD Range (JB CHS‐W only).

w. Programs, budgets, and funds compliance monitoring at the Subpart X Permitted

Northside OB/OD Range (JB CHS‐W only).

x. Manages the EESOH‐MIS Hazardous Waste Tracking System to include accurate data for container storage areas, waste profiles, and disposal manifests.

3) 628 AW/SEG (Safety):

a. Inspects HWIAPs and HWAS’s during the regular, annual ground safety inspections including MICT.

b. Records all findings and ensures deficiencies identified are corrected.

4) 628 CES/CED (Explosive Ordnance Disposal Flight):

a. Coordinates all ordnance disposals at Northside OB/OD Range with 628

CES/CEIE.

b. Ensures that no ordnance is transported to JB CHS‐A for disposal/ detonation.

Such items must be transported to either one of the Conditionally Exempt Magazines (for later treatment) or the Northside OB/OD Range permitted facility

– both of which are at JB CHS‐W.

c. Maintains Range Logs of items treated at the Range, including items treated as part of an Emergency Response Operation.

d. Maintains the physical components of the Northside OB/OD Range (e.g.

Detonation Mound, Burn Pans, etc.) in accordance with the JB CHS‐W Subpart X Permit, and appropriate AF regulations.

5) Requirements for Commanders of Units That Generate Hazardous Waste:

a. The generating activity will request determination of all HW generated by submitting a Waste Stream Characterization Process Document (Attachment 2) for each waste stream, as provided in Section 5.3.

b. Provide safe equipment and locations for HWIAP/HWAS’s. Coordinate each location with 628 CES/CEIE, Wing Safety, and the Fire Department.

c. Obtain DOT compliant containers for HW Disposal with 628 CES/CEIE concurrence for type and volume of container purchased/utilized.

d. Ensure the management of HWIAP/HWAS’s complies with Federal and

State hazardous waste management regulations and this plan.

e. Designate personnel (including at least one primary and one alternate POC) to act as HWIAP/HWAS’s Managers/Crew Chiefs.

f. Allow appropriate facilities, shops, and equipment to be inspected for hazardous waste management regulatory compliance by 628 CES/CEIE and authorized State or Federal inspectors.

g. Ensure that all personnel that handle hazardous waste or who are otherwise involved in hazardous waste management receive initial hazardous waste training and annual refresher training.

h. Comply with tasking in Closure and Preparedness and Prevention sections of this plan.

6) HWIAP/HWAS’s Managers/Crew chiefs and alternates:

a. Assumes overall responsibility for management of the HWIAP/HWAS’s.

b. Maintains control over the HWIAP/HWAS’s such that only approved personnel can place wastes into the hazardous waste containers.

c. Ensures HWIAP/HWAS has proper signs/postings.

d. Ensures the HWIAP/HWAS has a spill kit.

e. Ensures an approved fire extinguisher is readily available if flammable hazardous waste is stored in the HWIAP/HWAS.

f. Ensures personal protective equipment is available at the HWIAP/HWAS.

g. Ensures secondary containment is used for containers holding liquids.

h. Performs and records required weekly inspections.

i. Ensures a current up‐to‐date Hazardous Waste Profile Sheet has been completed and is on‐file for all identified HW streams.

j. Completes all waste transfer documents to be transferred to the Permitted Waste

Storage Facility (JB CHS‐W only).

7) 628 CES/CEF (JB CHS Fire Department):

a. Provides a 24‐hour emergency response telephone number that is written on all hazardous waste manifests. In case of emergency, CEF will have all hazardous and non‐regulated waste shipment information on hand. 628 CES/CEIE will deliver copies of the waste manifests to CEF for every shipment. 628 CES/CEIE will provide CEF additional information regarding the shipments when necessary.

3. Waste Inventory

A. JB CHS Hazardous Waste Stream Inventories can be found on the eDASH website:

1. JB CHS‐A Inventory can be found at the following link:

https://cs1.eis.af.mil/sites/edash‐ ins1/charleston/Shared%20Documents/Hazardous%20Waste%20(JB%20CHS‐ AB)/JB%20CHS%20Air%20Inventory%20of%20Hazardous%20Wastes.pdf

2. JB CHS‐W Inventory can be found at the following link:

WS)/Permab_C_Tables.pdf

3. JB CHS‐W Inventory of Explosive Hazardous Wastes can be found on page C‐52 at the following link:

WS)/Permab_C_Tables.pdf

4. Waste Analysis Plan

A. The Waste Analysis Plan (WAP) for JB CHS as required by 40 CFR 264.13(a), (b) and (c) and, 40 CFR 270.14(b)(3), State of South Carolina Hazardous Waste Management Regulations, and the Air Force Policy provides the basis for identifying and characterizing all JB CHS hazardous waste streams that are generated within property boundaries per 40 CFR 262.11.

B. The JB CHS Air WAP is intended to comply with Federal and South Carolina RCRA requirements and includes specific requirements for the identification and evaluation of

Hazardous wastes at the base. 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. The hazardous waste profile sheet, Form 1930, is provided in Attachment 2.

1. The WAP describes detailed procedures for obtaining physical and chemical analyses from all associated waste generating activities at JB CHS including procedures for selecting waste parameters for analysis and rationale, selecting waste sampling methods, identifying analytical methods, and evaluating hazardous waste streams’ analysis frequency.

2. Hazardous Waste Characterization Process: Hazardous waste characterization will involve three sequential steps:

a. Waste Identification – This is a process in which all waste generated at JB CHS are identified. The waste generator should ask the following questions to determine if they have a waste stream that must be evaluated:

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

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

b) Is it an unintended or unusable byproduct?

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

d) Is it produced by cleanup at a previously uncontrolled waste site?

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 (see 40 CFR 261.2).

3. Is it a hazardous waste? If the material is a solid waste, the solid waste should be evaluated to determine if it is a hazardous waste. A material is a hazardous waste if it has not been excluded from regulation and:

a) It is a characteristic hazardous waste (e.g., ignitable, corrosive, reactive, or toxic) per 40 CFR 261 Subpart C or,

b) It is a listed hazardous waste in 40 CFR 261 Subpart D (as defined in Glossary) or,

c) It is a mixture of a listed hazardous waste and solid waste?

d) SPECIAL NOTE: This evaluation can be conducted by either using the waste generator's knowledge of the hazard characteristics of the waste in light of the materials or processes used, or by analytical testing as described in 40 CFR 261 and this WAP.

b. Waste Evaluation: Waste evaluation is the process of determining which of the wastes identified in the first step may be classified as hazardous wastes.

This process can be conducted either by using the generator's knowledge of the waste or by analytical testing. In either case, the evaluation must be based on the EPA solid waste and hazardous waste definitions (refer to Glossary).

1) Analytical testing is required at JB CHS for all process waste streams (i.e., an unintended or unusable byproduct of a process used by a shop). Testing is not normally required for unusable materials (e.g., expired, unused commercial chemical products or laboratory chemicals in their original, marked containers). At a minimum, waste analysis must contain all the information necessary to treat, store, and dispose of the waste.

2) The generator must request a hazardous waste determination through the 628 CES/CEIE Hazardous Waste Program Manager, who will evaluate the waste based on the generator’s knowledge of the waste and the definitions provided in Attachment 2 and Section 4.A. &B.B. above. For new and a re‐evaluation of existing waste streams, shops must request this determination as soon as the waste is generated and prior to it leaving the waste generating area (Refer to Section 5.B..5. c., Determination and Turn‐In of Hazardous Waste).

3) If it is not possible to determine if the waste is hazardous based on existing data (e.g. SDS, product data), then the Hazardous Waste Program Manager will complete a Sample and Analysis Request Form (Attachment 4) identifying which analytical tests are required and the rationale. The materials used as well as the waste generating process will be considered when selecting analytical parameters [e.g., paint sludge from a paint stripping process would be analyzed for TCLP metals, total volatile organic compounds (TCLP analytes as well as underlying hazardous constituents), and ignitability.

4) The completed form is submitted to a contractor, who collects the sample, places a sample information label on the drum, and submits the sample to the laboratory for analytical testing. Sampling and analysis must be conducted in accordance with the requirements specified in Appendices I, II, and III of 40 CFR 261. Specific analytical test methods will be selected by the 628 CES/CEIE Hazardous Waste Program Managers. The analytical work for JB CHS waste streams will be performed by certified Air Force or contract laboratories.

5) Frequency of analysis. Each waste stream is evaluated at the time of initial generation, per 40 CFR 262.11. Process waste streams will be sampled on a quality assurance basis to ensure that waste streams are accurate and up to date and evaluations will be repeated when any process or operation generating the waste has changed. This includes a change in the product(s) used during the generation of the waste.

6) Sampling Protocol. A representative sample of the waste stream will be obtained by a contractor using the EPA procedures specified in Appendix I of 40

CFR 261.

c. Results, interpretation and documentation. The analytical results must be interpreted to determine if tested waste streams are hazardous according to EPA or State definitions. The interpretation will be based on EPA regulations on the identification and listing of hazardous waste in 40 CFR Part 261. The generator must also determine if the waste must be treated before it is land disposed. This is done by determining if the hazardous waste meets the treatment standards in 40

CFR 268.40, 268.45, and 268.49.

1) The Hazardous Waste Program Manager is responsible for interpreting the analytical test results. The results of any used oil analyses will be compared to 40 CFR 279.11 to ensure that the material meets the specifications for used oil (e.g., less than 1000 ppm of total halogens).

2) Environmental Element (628 CES/CEIE) will use the analytical results as well as the generating activities waste process knowledge to complete or update an existing form 1930 and place it in the EESOH‐MIS database accordingly. All hazardous waste streams will be labeled with the hazardous waste label (Attachment 5), once they are characterized as hazardous on the profile sheet.

628 CES/CEIE will also utilize form 1930 for developing profiles for non‐RCRA wastes. A non‐RCRA waste label (Attachment 6) is required for non‐RCRA waste streams.

3) A Waste Profile Sheet must be created or updated by 628 CES/CEIE whenever a process change or request for analysis affects the characteristics of a waste stream.

d. Permit Restrictions. If a waste from a new or changed process is identified as having an EPA waste code number that does not appear on the facility permit, 628 CES/CEIE shall request approval from SCDHEC to modify the permit if the waste will be stored for more than 90 days or placed in the hazardous waste storage facility. It is not necessary to change the permit if the waste is to be held for less than 90 days.

e. Reporting and Record keeping Requirements for Land Disposal Restriction Regulations. Land disposal restriction (LDR) regulations, published in 40 CFR 268 require a generator that is managing a LDR waste, which 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.

1) LDR Forms to Vendors for Wastes Shipped Off‐site. If a waste does not meet the treatment standards in 268.40, 268.45, or 268.49 the generator must send a one‐time written notice, at minimum, to each treatment, storage, or disposal facility receiving the waste. A copy of this notice must be retained in 628 CES/CEIE files. A new notification will be provided whenever there is a change in the waste profile or treatment facility. The procedure for preparing LDR forms to vendors for hazardous wastes shipped off‐site is outlined below.

a) 628 CES/CEIE shall provide the vendor with a copy of the waste profile data, including the LDR determination, for each waste stream so that LDR forms may be completed.

b) 628 CES/CEIE will review the LDR forms, which are drafted by the vendor, to ensure that the requirements of 40 CFR 268 have been met for each waste stream. These requirements may include, but are not limited, to the following:

i. The notice for restricted waste not meeting treatment standards in 40

CFR 268.41 through 268.43, or exceeding prohibition levels in 268.32 or RCRA Section 3004(d), will include all information required by the Generator Paperwork Requirements Table in 268.7(a)(4).

ii. If the waste meets the treatment standard for land disposal, then 628

CES/CEIE will ensure that the notice also includes a certification statement, that is drafted as specified in 268.7(a) (3) (i).

iii. For lab packs to be shipped off‐site, 628 CES/CEIE will ensure that the generator paperwork requirements in 268.7(a) (9) have been met.

iv. In the rare instance, that a case‐by‐case extension under 268.5 or a petition to allow disposal under extreme circumstances in 268.6 is required, 628 CES/CEIE will ensure that the requirements in 268.7(a) (4) are met.

v. 628 CES/CEIE comments will be provided to the vendor prior to the day of shipment so that the LDR forms may be revised, as necessary.

vi. All notifications and certifications will be prepared and maintained per 268.7.

c) On the day of shipment, 628 CES/CEIE will perform a final review of the LDR forms, and obtain a copy of the forms to include with the manifest in the facility’s file. If the waste meets the treatment standard for land disposal, then 628 CES/CEIE will sign the certification s tatement included in the notice.

2) One Time Notice to File for Excluded Materials. For an area generating an excluded, exempt or recycled waste, 628 CES/CEIE will generate and file a one‐ time notice, at a minimum, 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 area's waste management file. Examples of wastes for which a One Time Notice To File is required under 40 CFR 268.7(a)(7) are as follows:

a) Characteristic sludge for reclamation 40 CFR 261.2(c) (3).

b) Spent Lead‐acid batteries that are being reclaimed 40 CFR 261.6(a) (2) (iv).

c) Acetone rags with no free liquids.

d) 40 CFR 261.3(a) (2) (iii), wastewater with de minimus levels of solvents.

e) 40 CFR 261.3(a) (2) (iv).

f) Used oil 40 CFR 261.6(a) (4).

g) De minimus exemption for metalworking fluids.

h) Freon contamination under 40 CFR 261.3(a) (2) (v) (B).

i) Wastewater that is mixed with domestic sewage going to a publicly‐owned treatment works (POTW) for treatment 40 CFR 261.4(a) (1) (ii).

j) Industrial wastewaters that are point sources and are subject to regulation under Section 402 of the Clean Water Act 40 CFR 261.4(a) (2).

k) Non‐terne plated used oil filters that have been hot‐drained 40 CFR

261.4(b)(13).

l) Scrap metal 40 CFR 261.6(a)(3)(ii),

m) A new notice will be generated whenever there is a change in the waste profile.

3) Record keeping Requirements. A copy of all notices, certifications, waste analysis data, and other documentation will be maintained by 628 CES/CEIE on‐site for at least three years from the date the waste was last sent to an off‐ site treatment, storage, or disposal facility.

3. Waste Parameter Selection: Waste parameters selected are based on the suspected hazardous waste characteristics of the waste. When determining which analyses are to be performed for a particular waste stream, the following criteria will be used:

a. Flash Point. Flash Point is determined through a test procedure that identifies w h e t h e r a waste is ignitable (D001). Ignitable hazardous wastes have flash points less than 140 °F. Some hazardous waste streams contain varying concentrations of ignitable solvents that have the potential to lower the waste's flash point to less than 140 °F. Because process knowledge is not adequate to accurately predict the flash point of these waste streams, the waste must be tested to determine ignitability. If the waste is a liquid, the sample will be analyzed to determine ignitability using SW‐846 Method 1010 or 1020. If the waste is a solid, then ignitability will be determined by SW‐846 Method 1030.

b. Corrosivity. In order for a waste to be considered corrosive (D002), it must be a liquid. Generator knowledge, a visual inspection, or the Paint Filter Test (SW‐846 Method 9095) will be used to determine if the waste is a liquid. If it is an aqueous liquid (contains water) and generator’s knowledge of the waste indicates that it may be corrosive (i.e., product data or other information suggests that the pH of the w a s t e may be less than 2 or greater than 12), the waste will be analyzed by SW‐846 Method 9040. If the waste is a non‐aqueous liquid, then generator knowledge will be used to evaluate corrosivity; if historical evidence or other information indicates that the waste may be corrosive, then the waste will be analyzed using SW‐846 Method 1110 (Corrosivity towards Steel).

c. Reactivity. If the waste stream previously contained cyanide, sulfide, or historical evidence or other information indicates that it may be reactive, then reactivity (D003) will be determined. SDS and other product data will be reviewed to determine if cyanide or sulfide analysis is required. Reactivity will be determined per Section 7.3 of SW‐846.

d. Toxicity Characteristics. If an extract from a representative sample of waste, which when tested in accordance with the Toxicity Characteristic Leaching Procedure (TCLP) (SW‐846 Method 1311 as referenced in Appendix II of 40 CFR 261), contains any of the analysis at a concentration equal to or greater than the regulatory level listed in Table 1 of 40 CFR 261.24 (Attachment 9), the waste is a hazardous waste.

All new and non‐recurring waste streams, except for laboratory chemicals and unused commercial chemical products, will be evaluated for toxicity characteristics.

The analytical methods selected will be based on the generator’s knowledge of the waste (i.e., methods for those analysis suspected of being present in the waste at concentrations greater than the regulatory limit). If toxicity characteristic analyses will be performed and the waste may be sent offsite for land disposal, then an evaluation of Underlying Hazardous Constituents (UHC) must be performed (see next paragraph below).

e. Underlying Hazardous Constituents. As per 40 CFR 268.7(a), for all characteristically hazardous wastes that may be land disposed, the generator must evaluate whether any of the constituents listed in 40 CFR 268.48 are expected to be present above treatment standards. Wastes will be analyzed when constituents are suspected of being present at or above Universal Treatment Standards (UTS). The analytical methods selected will be based on the generator’s knowledge of the waste (e.g., product data).

1) Organic Compounds. Many organic compounds are included in the UHC list.

Treatment standards are typically based on total analyses; however, some compounds require TCLP analyses (e.g., methanol). Total analyses, instead of TCLP, will be conducted if the waste is suspected to contain toxic characteristic organics as defined by 40 CFR 261.24 and organic UHCs. Results from the total analyses will be compared to the TCLP limits. For liquids (less than 0.5% TSS), total analysis results are equivalent to TCLP results. For solids, the results of the total analysis can be divided by 20 (the dilution factor used in TCLP analyses for solids) prior to comparison to toxicity characteristic standards presented in 40 CFR 261.24. This evaluation assumes a worst case condition where all constituents are completely leached (100%) from the waste during extraction. If results indicate that toxicity characteristic standards may have been exceeded for solids, taking into account the dilution factor, then a TCLP analysis may be conducted to determine actual leach ability, if the EPA‐established holding time criteria can be met.

2) Nickel. Since nickel is a common alloy, wastes that are suspected of containing toxic characteristic inorganics, as defined by 40 CFR 261.24, will be analyzed for nickel by SW‐846 6010. Total nickel analyses will be conducted for metal bearing wastewaters, while TCLP nickel will be conducted for any metal bearing non‐wastewaters (solids and sludge).

f. Paint Filter Test. To determine if free liquids are present in a container, generator’s knowledge (process knowledge, product data), a visual inspection, or the Paint Filter Test is conducted to characterize the waste to ensure proper disposal. If free liquids cannot be determined based on the generator’s knowledge or a visual inspection, then the Paint Filter Test (SW‐846 Method 9045) is to be conducted on the waste to demonstrate that no free liquids exist in the container.

g. Used Oil. Used oil is not regulated as a hazardous waste if the total halogen concentration is less than 1000 ppm (see footnote 2 to Table 1 of 40 CFR 279.11).

To determine that used oil specifications for energy recovery in 40 CFR 279 have been met, a representative sample of the used oil will be analyzed for arsenic, cadmium, chromium, lead, flashpoint, total halogens, and PCBs.

4. Quality Assurance and Quality Control (QA/QC). The purpose of the QA/QC program is to produce data of known quality that satisfies the objectives of the sampling event.

The QA/QC program followed by the base is presented in the Armstrong Laboratory Services Guide, AL/OE‐TR‐1994‐0136. Adherence to the procedures presented in this document will ensure that data of sufficient quality has been obtained to evaluate the waste stream

5. WAP Revision. The JB CHS WAP will be evaluated and reviewed annually by 628

CES/CEIE to ensure that the most up‐to‐date procedures are followed.

C. The Joint Base Charleston Weapons Analysis Plan is similar and may be found at the following link:

https://cs1.eis.af.mil/sites/edash-ins1/charleston/Shared%20Documents/Hazardous%20Waste%20(JB%20CHS-WS)/JB%20CHS%20Weapons%20Waste%20Analysis%20Plan.pdf https://cs1.eis.af.mil/sites/edash-ins1/charleston/Shared%20Documents/Hazardous%20Waste%20(JB%20CHS-WS)/JB%20CHS%20Weapons%20Waste%20Analysis%20Plan.pdf https://cs1.eis.af.mil/sites/edash-ins1/charleston/Shared%20Documents/Hazardous%20Waste%20(JB%20CHS-WS)/JB%20CHS%20Weapons%20Waste%20Analysis%20Plan.pdf

WS)/JB%20CHS%20Weapons%20Waste%20Analysis%20Plan.pdf

5. HW Management Procedures

A. Specific Waste Management Procedures: Hazardous waste is accumulated at JB CHS within designated Hazardous Waste Initial Accumulation Points (Satellite Accumulation Areas) or Hazardous Waste Storage Areas (< 90 Day sites) and stored at the RCRA‐ permitted storage facilities (JB CHS‐A Hazardous Waste Storage Yard, Bldg. 691 and JB CHS‐W Hazardous Waste Container Storage Facility, Bldg. 2332). Hazardous Waste may not be transported from the Air Side to the Weapons Side or vice versa. Hazardous waste may only be accumulated and temporarily stored at these pre‐designated areas.

Each type of accumulation area must comply with the associated requirements outlined in this section. Each HWIAP/HWAS must comply with the following requirements:

1. Hazardous Waste is accumulated in either an HWIAP or an HWAS. A generating unit may have either or both types of waste storage areas; however, the rules for managing these sites are different.

a. An HWIAP is an area where waste is initially accumulated under control of the shop supervisor of the process generating the waste. The maximum volume of a hazardous waste permitted (for continuing accumulation) at each HWIAP is 55 gallons or one quart of acutely hazardous waste (P‐listed waste). For JB CHS, this means although there is a volume limit, there is no time limit on how long the waste can be accumulated at an HWIAP. Once the volume limit is reached, the waste must be moved to the TSDF (Air) or TSDF (Weapons) within 3 days. If an additional HWIAP is ever needed, the HWIAP crew chief/manager shall coordinate with 628 CES/CEIE to select and design the location of the HWIAP to minimize any threat to human health and the environment.

b. A hazardous waste HWAS is an area near the waste generating activity where hazardous waste is accumulated in containers or tanks for a period of up to 90 days.

Each container has a 90 Day storage limit, with either the start date from the waste first is placed into the container (if accumulating in the 90 Day site), or the fill date (if waste was accumulated and received from an HWIAP). There is no volume limit at a 90 Day Site.

2. Location. The area used for the accumulation of hazardous waste, must be one of the areas specified in Attachment 1. If an additional HWIAP/HWAS is required, the location must be selected in coordination with the Base Hazardous Waste Program Manager.

The 628 CES/CEIE Hazardous Waste Program Manager will designate a location for the point that will minimize the threat of the waste stream to human health or the environment in the event of a release. The Environmental Element (628 CES/CEIE) will maintain a current copy of Attachment 1. JB CHS will comply with the following physical requirements for the location of HWIAP/HWAS’s:

a. The HWIAP container(s) must be located at or near the point of generation where the waste initially accumulates, which is under the control of the operator of the process generating the waste.

b. EPA requirements for the location of HWIAP/HWAS’s (40 CFR 262, Subpart C).

https://cs1.eis.af.mil/sites/edash-ins1/charleston/Shared%20Documents/Hazardous%20Waste%20(JB%20CHS-WS)/JB%20CHS%20Weapons%20Waste%20Analysis%20Plan.pdf

c. State requirements for the location of HWIAP/HWAS’s (R.61‐ 79.262, Subpart C).

d. HWIAP/HWAS Crew Chiefs/Managers must obtain pre‐approval by the Base

Fire Department, Wing Safety, and the Base Hazardous Waste Program Manager for the location of new sites. Approval must take into consideration potential environmental consequences if hazardous waste is released from the HWIAP/HWAS during a spill, fire or explosion.

e. Containers placed at HWIAP/HWAS’s which hold ignitable or reactive wastes must be located at least 50 feet inside the JB CHS property boundary. These containers must also be kept away from sparks, open flames, extreme heat, or other sources of ignition.

f. For incompatible wastes, segregated containment must be provided, by using either separate containment areas or by means of separate diked areas, or sloped containment to separate sumps. Hazardous chemical reactions that cause heat, fire, explosion, pressure, or the evolution of toxic or flammable decomposition products due to incompatible chemical reactions must be prevented. If unsure whether a waste is compatible with the container itself, contact the Hazardous Waste Program Manager before placing waste in the container. The mixing of incompatible material may have the potential consequence as noted. 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 material.

g. Hazardous wastes must not be located near anything with which they are incompatible. For example, lead‐acid batteries should not be located near any aluminum structures or surfaces because contact between acid and aluminum may produce flammable hydrogen gas and could lead to a fire or explosion.

Containers holding wastes that are incompatible with any other wastes or material present must be physically separated from the other materials by means of a dike, berm, or wall.

h. "No Smoking" signs must be placed conspicuously wherever there is a hazard from ignitable or reactive waste.

i. At outdoor HWIAP/HWAS’s, containers must be protected from direct sunlight and precipitation by means of a roof, tarpaulin, or similar device.

j. Drums must be placed on pallets (if practical) to allow for ease of removal when full and to keep them…