27_SOW_Hazardous_Waste_Management_Plan_-_May-17.pdf

U. S. AIR FORCE HAZARDOUS WASTE MANAGEMENT PLAN

Cannon Air Force Base and Melrose Air Force Range

5/31/2017

HAZARDOUS WASTE MANAGEMENT PLAN

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.

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 – 90-Day Container Log Appendix C – Template - Request Samples for Analysis Appendix D – Hazardous Waste Profile Sheet Appendix E – Sample Waste Process Description Appendix F – AF Form 2005 Appendix G – Sample Container Labels Appendix H – Sample HW Monitor Appointment Letter Appendix I – Inspection Checklists Appendix J – Contact List

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:

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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

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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

This plan provides policies and procedures for the management of hazardous wastes generated during base operations at Cannon Air Force Base (AFB) and Melrose Air Force Range (AFR). Cannon AFB and Melrose AFR are committed to the proper management of hazardous waste from the point of generation (point at which it becomes a waste) to the point of ultimate disposal. The scope of the plan is the implementation of the U.S. Environmental Protection Agency’s (EPA) “cradle-to-grave” philosophy for managing hazardous wastes.

2.0 INSTALLATION PROFILE

Installation Profile

Scope of Plan Cannon Air Force Base and Melrose Air Force Range Office of Primary Responsibility

(OPR)

27 SOCES/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 Teddy “Mark” Suggs Alternate HW Program Manager Anita Lafuente Emergency contacts Teddy “Mark” Suggs

575.904.6734 teddy.suggs.1@us.af.mil

Anita Lafuente 575.904.6746 anita.lafuente@us.af.mil

Ronald Lancaster 575.784.1146 ronald.lancaster@us.af.mil

Waste registration numbers Cannon AFB: NM7572124454 Melrose AFR: NM5572124456

HW generator status Cannon AFB: Large Quantity Generator (LQG) Melrose AFR: Conditionally Exempt Small Quantity Generator (CESQG) or Very Small Quantity Generator

(VSQG)

Universal waste handler status Cannon AFB: Small Quantity Handler of Universal Waste Melrose AFR: Small Quantity Handler of Universal Waste

Permitted HW operations NA Federal or FGS regulatory references 40 CFR 260 - 279 State and local regulatory agencies New Mexico Environment Department (NMED) State and local regulatory references 20.4.1 – 20.4.3 NMAC Approved HW disposal contractors DLA HW accumulation sites Hazardous Waste Accumulation Site (HWAS), also referenced as Central Accumulation Area (CAA), located at Building 226

HW accumulation time limits Cannon AFB: 90 Days Melrose AFR: None

HW generator reporting frequency Cannon AFB provides a Hazardous Waste Annual Business Fee and a Waste Minimization report to NMED annually.

Cannon AFB also provides a waste report biannually to NMED by March 1st of each even-numbered year.

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

4.1 27th Special Operations Wing Commander (27 SOW/CC) –

Ensures that a written HWMP is established and maintained to provide personnel with procedures and responsibilities to manage hazardous wastes consistent with all applicable laws and regulations;

Ensures compliance with Federal, state, local, and Air Force hazardous waste regulations;

Ensures all base organizations implement the HWMP;

Delegates or designates in writing the authority to delegate DLA Distribution representative and

27 SOCES/CEIE trained personnel to sign Uniform Hazardous Waste Manifests for off-site waste shipments; and

Signs or designates, in writing, a designated responsible official to sign all Environmental Element regulatory reports and receive regulatory agency administrative orders that may be issued to the base.

4.2 Staff Judge Advocate (27 SOW/JA) –

Provides legal interpretations of the hazardous waste regulatory requirements;

Coordinates on all correspondence relating to regulatory enforcement or compliance actions;

Attends meetings with regulatory agencies and provides legal advice on environmental issues;

and Informs Environmental Element of precedents that decide points of law regarding hazardous waste.

4.3 Air Force Civil Engineer Center (AFCEC), Environmental Directorate (AFCEC/CZ) –

AFCEC/CZ is the OPR for implementing policy/guidance, allocating resources, and overseeing execution of the Solid and Hazardous Waste Management Environmental Compliance Program throughout the Air Force.

Provides technical expertise, resources, and regulatory support for the SW and HW programs;

Reviews all Air Force RCRA permit applications/renewals before submission to regulators for approval;

Reviews applications for waivers from use of DLA HW contracting mechanism;

Provides functional management support and oversight for the sustainment of the Air Force standard HW Tracking System, EESOH-MIS.

4.4 Public Affairs (27 SOW/PA) -

Advises on public affairs aspect of hazardous waste management; and Acts as the only spokesperson and releasing agent to civilian news media regarding a HW incident/accident. If media contact a base agency, they will be referred to 27 SOW/PA without comment regarding the incident/accident.

4.5 Ground Safety (27 SOW/SEG) -

Provides technical advice on personnel safety aspects of hazardous waste management.

4.6 Shop Chief -

Designates Hazardous Waste Monitors for each Initial Accumulation Point (IAP).

4.7 Supervisors of Personnel Generating Hazardous Waste -

Attends hazardous waste training if personnel they supervise generate hazardous waste; and Ensures that all personnel who work with hazardous waste receive and successfully complete annual hazardous waste training either through Environmental Element instructor-based training or appropriate training module available through ESOH-TN (or ADLS or other available CBT equivalent).

4.8 Primary and Alternate Hazardous Waste Monitors –

Submits Waste Process Descriptions for each waste stream to 27 SOCES/CEIE before accumulating the waste stream;

Notifies the Hazardous Waste Program (HWP) Manager of the Primary and Alternate Hazardous Waste Monitors assignments;

Establishes IAP, if required, after Environmental Element approves the IAP;

Ensures each IAP displays a posted sign identifying the location as an IAP;

As required, conducts inspections at IAPs;

Conducts semi-annual program inspections;

Ensures containers are in good condition and compatible with contents;

Ensures only Department of Transportation (DOT)-approved containers for the waste type are used;

Ensures each IAP container is kept closed except to add or remove waste;

Ensures each IAP container is properly labeled in accordance with the Hazardous Waste

Management Plan (HWMP) with the contents of the container and the words “Hazardous Waste;”

Maintains a hard copy of the HWMP or access to an electronic copy of the Cannon AFB HWMP;

and Maintains section’s Hazardous/Universal Waste Continuity Book (see Section 6.0 Recordkeeping and Reporting).

4.9 Generators of Hazardous Waste –

Identifies all waste streams and process changes that may result in changes in the types and amounts of waste generated to Environmental Element;

Prepares written Waste Process Descriptions and submits copies to the HWP Manager who will coordinate the development of the associated HW profile, to be completed by the on-site contractor;

Complies with all Federal, state, local, and Air Force regulations regarding hazardous waste management, including the implementation of this plan;

Provides access to appropriate facilities, shops, and equipment for Environmental Element and authorized state, Federal, and Air Force inspectors and assessors;

Ensures appropriate records are maintained;

Retains IAP appointment letters (current and inactive) for three (3) years past the term of employment;

Cross-references the location for the shop hazardous materials Authorized User List;

Maintains a Hazardous/Universal Waste Continuity Book to retain all records required in support of the work center’s HW program as required by this Plan;

Maintains DRMS Form 1930 (Hazardous Waste Profile Sheet) or electronically generated equivalent;

Maintains records of initial and annual hazardous waste training; and Maintains AF Forms 2005 (or electronic equivalent generated through EESOH-MIS).

4.10 Installation Management Flight Environmental Element (27 SOCES/CEIE) –

The Base Civil Engineer, through the Installation Management Flight/Environmental Element (27 SOCES/CEIE), is responsible for the following:

Provides overall management of the hazardous waste program;

Develops installation-specific policy and provides technical guidance and oversight for all aspects of hazardous waste management for all activities on the installation including Air Force and non- Air Force tenants at Cannon AFB and Melrose AFR;

Serves as the OPR for developing and implementing the HWMP;

Serves as liaison with regulatory agencies on all hazardous waste issues (agencies include EPA

Region VI, NMED HWB, DOT, and local agencies);

Provides technical guidance and oversight to Cannon AFB and Melrose AFR personnel to ensure compliance with Federal, state, local, and Air Force requirements;

Reviews the HWMP annually and updates as needed or when changes occur;

Ensures adequate hazardous waste characterization and documentation based on the waste-generating activity and requests analytical services, as needed;

Provides hazardous waste management training or online resources;

Provides regulatory oversight for the contractor-operated Cannon AFB HWAS;

Provides oversight for inspections of hazardous waste operations to verify compliance with hazardous waste regulations;

Coordinates with DLA Disposition Services and/or contractors for disposal and/or treatment of hazardous waste;

Ensures information in EESOH-MIS is current and correct.

Prepares and/or coordinates biennial reports for submittal to EPA and/or NMED Hazardous

Waste Bureau (HWB) and prepares all other hazardous waste reports as required;

Develops and updates the waste analysis plan (WAP);

Maintains the basis for Waste Stream Characterization for all processes including documented user knowledge, SDSs, and analytical results, if applicable, and forwards documentation to the current year until the information is replaced and is inactive;

Maintains copies of the following documents:

o Manifests;

o Land Disposal Restriction (LDR) notices;

o Biennial Reports;

o Annual waste generation metrics;

o DD Form 1348-1A or electronic equivalent (turn-in documents);

o Hazardous Waste Profile Sheets (HWPS);

o Hazardous waste analytical sample results;

o Regulatory reports and correspondence; and o Records of all inspections and Staff Assistance Visits (SAVs).

Notifies NMED HWB within 24 hours of a response, and provides follow-up documentation within 10 days of a response.

4.11 Hazardous Waste Managers at Hazardous Waste Accumulation Site –

Ensures the accumulation site complies with this HWMP and all Federal, state, and Air Force regulations;

Ensures any person handling waste has received the required hazardous waste training;

Coordinates all Cannon AFB HWAS procedures through Environmental Element;

Ensures weekly inspections, not to exceed seven days, are done on each accumulation site;

Maintains a current container log that includes the following information (refer to Appendix B):

o Organization, office symbol, and phone number of the generator;

o Contents of container, sample number if applicable;

o Container number and weight;

o Date and location waste was accepted; and o Location of container.

Ensures containers are compatible with waste they contain and are in good condition;

Ensures each container is kept closed except to add or remove waste;

Ensures each waste container displays the proper label (hazardous waste, non- RCRA regulated), contents of the container, and accumulation start date if it contains hazardous waste;

Ensures immediate remedial action is taken for leaks or spills of waste;

Ensures the accumulation site has required fire protection, spill control, and decontamination equipment; communication or alarm system; and aisle space for emergency equipment;

Ensures equipment is tested and maintained to assure its proper operation in time of emergency;

Ensures the accumulation site has a contingency plan as specified in 40 CFR 265, Subpart D;

Acts as HWAS first responder to incidents until emergency coordinators arrive on- site;

Notifies Environmental Element of any change in facility equipment, operations, or processes;

Maintains a copy of the container (drum) log for three years (contractor submits originals to

Environmental Element).

4.12 Hazardous Waste Contractors/Agents (HWAS Personnel) (27 SOCES/CEIE) -

Manages the Cannon AFB HWAS to comply with RCRA requirements for Hazardous Waste Accumulation Sites;

Picks up hazardous waste from industrial shop IAPs;

Logs waste information into EESOH-MIS;

Provides pre-labeled, DOT-approved hazardous waste containers appropriate for the waste stream to the IAP;

Provides the HWP Manager with reports and original document records for the Cannon AFB

HWAS operating records;

Develops HWPS;

Completes HW labels as necessary for off-site highway shipment;

Coordinates pick-up of waste by the DLA-DS representative after all paperwork is complete;

Diverts waste using a variety of recycling techniques, such as aerosol can puncturing, oil and antifreeze recycling, etc.;

Complies with their Statement of Work and contract requirements; and Manages the hazardous waste analysis contract.

4.13 DLA Dispositions Services (DLA-DS) -

DLA-DS provides HW disposal services for Cannon AFB. DLA-DS arranges for approved contractors to transport hazardous waste to EPA-permitted Treatment, Disposal, and Storage Facilities (TDSFs) for treatment and permanent disposal.

Inspects waste disposal turn-in documents to ensure information is complete and accurate;

Ensures that the waste is properly prepared for transport according to EPA and DOT regulations;

Initiates and monitors compliance with hazardous waste disposal contracts according to RCRA, DOT, and other applicable Federal, state, local, and Air Force regulations;

Ensures disposal contractors comply with RCRA LDR requirements based on information supplied on the manifests, HWPS, and LDR notices;

Maintains records and files relating to the characterization and disposal of HW, including the

HWPS, analytical results and/or SDSs, manifests, and LDR notices;

Meets applicable Federal, state, local, DLA, and Air Force training requirements; and Ensures only qualified HW disposal contractors are awarded contracts through DLA-DS

Contracting.

4.14 Base Fire Chief (27 SOCES/CEF)

Provides technical guidance on fire protection aspects of hazardous waste management and training;

Performs annual inspections of all facilities where hazardous waste is generated to ensure fire protection regulations are being followed; and

Provides initial response to hazardous materials/waste spills.

4.15 Bioenvironmental Engineer (27 SOAMDS/SGPB)

Ensures the HWMP is carried out in compliance with Air Force Occupation Safety and Health standards and current medical regulations;

Provides guidance for appropriate personal protective equipment (PPE) and cleanup of spills; and Serves as OPR for the disposal of radioactive wastes.

4.16 Contracting Officer (27 SOCONS/LGC)

Ensures that the Staff Judge Advocate and DLA-DS review all local hazardous waste disposal contracts; and

Ensures all contract specifications require that any contractor-generated waste is the responsibility of the contractor and will be managed as required by Federal and State regulations.

4.17 Explosive Ordnance Disposal (27 SOCES/CED)

Provides immediate response to requests from law enforcement and other agencies to respond to emergencies involving explosive substances (e.g., explosive devises, military ordnance, and explosive chemical) by detonation on-site or removal to a secure location for detonation.

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

5.1 Training –

Effective training will help personnel avoid common compliance problems associated with 27 SOW operations.

Web-based training and assessment system is accessible from any computer with Internet access and available through Environmental, Safety, and Occupation Health – Training Network (ESOH-TN).

ESOH-TN (or ADLS or other available CBT equivalent) provides environmental compliance information and training to users requiring an understanding of environmental laws, regulations, and policies to complete their jobs successfully. ESOH-TN (or ADLS or other available CBT equivalent) provides a starting place to understand legal requirements that apply to operations, but additional in-depth training may be required.

Training is also available through an instructor-based course that 27 SOCES/CEIE offers. This classroom training is available once per quarter. Contact the HWP Manager to schedule an instructor-based class.

5.2 Initial Training –

IAW Air Force Instruction (AFI) 32-7042, all personnel who work with hazardous waste and their supervisors must receive and successfully complete hazardous waste training within three months of beginning work with HW. Personnel must work under the supervision of a trained person until they have received training.

Instructor-based training is recommended for HW handlers newly assigned to hazardous waste management responsibilities.

Upon completion of training, personnel will receive a certificate to document training. For those appointed as Hazardous/Universal Waste Monitors, proof of training must be filed in the Hazardous/Universal Waste Continuity Book.

5.3 Annual Training –

All personnel whose duties include working with hazardous waste must complete annual HW training.

The intervals between training must not exceed one year. Contact the HWP Manager if more information about initial or annual training is needed.

5.4 Hazardous Waste Accumulation Site Personnel Training–

Cannon AFB HWAS personnel, whether military, civilian, or contractor shall ensure the required HW training and student/employee competency is accomplished for all personnel whose activities affect compliance at the HWAS before commencing these duties. 40 CFR 265.16 requires initial training, annual refresher training, and specific training records for personnel who manage HWASs.

The HWAS Manager is responsible for competency training of HWAS personnel on the topics listed below:

HW characterization;

Site-specific contingency plan and its implementation;

LQG regulatory requirements that apply to accumulating wastes for 90 days;

Universal waste regulations;

LDR regulations that apply to LQG;

Recordkeeping requirements, including those related waste characterization, manifesting, LDR requirements, and training;

DOT regulations applicable to individuals’ job duties.

Initial and annual refresher training should assist Cannon AFB HWAS Managers in maintaining proficiency in these topics. All topics need not be covered in each annual refresher as regulations associated with the topics do not change each year. Cannon AFB HWAS Managers must also receive DOT training relevant to the pre-transport operations they perform at least once every three years.

5.5 HWP Manager Training –

The HWP Manager oversees all HW management on base and maintains documentation of legally required training in the 27 SOCES/CEIE files for regulatory review. The HWP Manager shall also be familiar with the following topics:

HW characterization;

Site-specific contingency plan and its implementation;

LQG regulatory requirements that apply to accumulating wastes for 90 days;

Universal waste regulations;

LDR regulations that apply to LQG;

Recordkeeping requirements, including those related waste characterization;

manifesting, LDR requirements, training, etc.; and DOT regulations applicable to individuals’ job duties.

Annual hazardous waste courses from a variety of commercial and Air Force sources can be used to keep current on laws and regulations regarding hazardous waste. The HWP Manager will also receive DOT training at least once every three years.

5.6 Training Recordkeeping –

Training records for personnel working at the Cannon AFB HWAS must include the following:

Job title for each position at the facility related to hazardous waste management and the name of the employee(s) filling each job;

A written job description for each position;

A written description of the type and amount of both introductory and continuing training that will be given to each person fulfilling each position;

Records that document the required training or job experience has been completed; and Training records on current employees and records for former employees must be kept for three years from the last day of employment at the shop.

Personnel must retain a copy of their original proof of training and provide a current copy of the training records to the HWP Manager in 27 SOCES/CEIE within 10 business days after course completion. These records must be accessible for inspectors, assessors, and/or auditors to review (e.g., EPA, NMED HWB, and ESOHCAMP auditors, etc.).

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

Record* Retention Time** Citation 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

6.1 Recordkeeping –

The facility permits are the responsibility of the Installation Commander. Cannon AFB will track HW with the EPA HW manifest and will report HW management activities using EESOH-MIS.

These records are either maintained in the files at 27 SOCES/CEIE or at the Cannon AFB HWAS. The HWP Manager maintains the HWMP, which includes a table documenting the location of each type of record.

6.2 Training Recordkeeping –

Training records of current personnel must be kept until the closure of the site; and Training records of former personnel must be kept for 3 years from the date the individual last worked at Cannon AFB.

6.3 Waste Determination Records –

At Cannon AFB, waste determination records include the following:

Waste Process Descriptions;

SDSs, if applicable;

Analytical results including the chain-of-custody documents, QA/QC laboratory information; and

HWPS.

The HWP Manager and Cannon AFB HWAS personnel jointly maintain files organized by shop code and waste stream. Files include the information identified above as the waste determination record.

Hazardous Waste Monitors maintain copies of waste process descriptions and hazardous (or universal) waste profile sheets; analytical results and SDSs used as basis for waste determinations will be maintained by 27 SOCES/CEIE. SDSs are retained as the basis for waste determination for discarded, unused products. Chain-of-custody documents and laboratory QA/QC data are maintained with the analytical records, rather than in the shop waste stream files.

6.4 Reporting to NMED –

6.4.1 Hazardous Waste Reporting –

o RCRA requires hazardous waste generators and permitted facilities to submit specific reports regarding the types and quantity of wastes generated, environmental releases, and manifest irregularities. The HWP Manager shall oversee the submittal and maintenance of the records and shall make them available to appropriate state and federal inspectors upon request.

6.4.2 Annual Hazardous Waste Fee Report –

o Cannon AFB and Melrose AFR pay hazardous waste generation fees to NMED annually.

This report must be submitted to NMED no later than August 1 for the previous calendar year. These annual fees are intended to meet necessary expenses in the administration and operation of the state hazardous waste program. Hazardous waste fees are calculated on a per pound basis. In addition, Cannon AFB is required to pay a set annual business fee based on its status as a LQG.

6.4.3 Biennial Hazardous Waste Report –

o Cannon AFB ships hazardous waste off-site to a TSDF facility within the United States and, therefore, must prepare and submit a Biennial Report to NMED by March 1 of each even-numbered year IAW 40 CFR 262.41. This report includes:

Completed EPA Form 8700-12, RCRA Site Identification form;

The EPA identification number;

Name and address of the generator;

The calendar years covered by the report;

The EPA identification number of each transporter used;

The EPA hazardous waste number;

The DOT hazard class;

The quantity of HW shipped off-site;

A description of the efforts undertaken by Cannon AFB during the year to reduce the volume and toxicity of waste generated; and A description of any changes in volume and toxicity of waste compared to previous years.

6.5 Manifests -

The hazardous waste manifest tracks HW from the facility that generated the waste to TSDFs. The “cradle-to-grave” manifest ensures accountability for the waste shipment and verification that the appropriate TSDF received it. IAW 40 CFR 262.23, the generator must sign the manifest certification and obtain one copy of the handwritten signature of the initial transporter, the DLA-DS contractor, and the date the hazardous waste transporter accepted the waste. The DLA-DS contractor cosigns all hazardous waste and PCB manifests for waste sent through them for disposal. The Cannon AFB IC designates individuals authorized to sign the manifest in writing. DLA-DS and 27 SOCES/CEIE each keep one copy of the manifest until a signed copy is received from the TSDF.

When the shipment arrives at the TSDF, the TSDF signs the manifest confirming receipt of the waste.

The TSDF sends one copy of the signed manifest to DLA-DS. The DLA-DS contractor will then forward a copy to 27 SOCES/CEIE.

6.6 Exception Report -

IAW 40 CFR 262.42, if the base does not receive a copy of the manifest signed by the TSDF within 35 days from the date the transporter accepted the waste for shipment, DLA-DS must contact the transporter and/or TSDF to determine the status of the hazardous waste. An exception report must be submitted to NMED HWB if the base does not receive a copy of the manifest signed by the TSDF within 45 days of the date that the initial waste transporter accepted the waste. The HWP Manager prepares the exception report, if required, and maintains copies of the exception reports in the 27 SOCES/CEIE files.

6.7 Notification and Certification –

If a waste does not meet the treatment standards in 40 CFR 268 Subpart D, the generator must send one-time written notice, at a minimum, to each TSDF receiving the waste. A copy of this notice must be retained in the Hazardous Waste Program files. Be aware that the state receiving the waste may impose additional requirements. A new notification is required whenever the waste profile or treatment facility changes.

When a new waste stream is identified for shipment or an existing waste stream has changed, Cannon AFB provides the vendor with a copy of the waste profile data, including the LDR determination, for each waste stream so that LDR notifications may be completed. Cannon AFB personnel will review the LDR forms, which the vendor drafts based on the waste profile information provided to ensure that the requirements of 40 CFR 268 are met. These requirements may include the following:

The notice for restricted waste not meeting applicable treatment standards includes all information required by Generator Paperwork Requirements Table in 40 CFR 268.7(a)(4);

If the waste meets the treatment standard for land disposal, a certification drafted as specified in 40 CFR 268.7(a)(3)(i) is provided to the vendor;

LDR notices for lab packs provide either information specified in the Generator Paperwork Requirements Table or, if the alternate treatment standard for lab packs is used, Cannon AFB complies with the requirements in 40 CFR 268.7(a)(9), including certifying that wastes in Appendix IV of 40 CFR 268 are not present.

Although it is unlikely that a case-by-case extension under 40 CFR 268.5 or a petition to allow land disposal of prohibited waste will be required, Cannon AFB personnel will ensure compliance with 40 CFR 268.7(a)(4) if these exceptions are used.

Comments on vendor-prepared LDR notices are usually provided to the vendor prior to the day of shipment so that the LDR forms can be revised, as necessary. All notifications and certifications are prepared and maintained per 40 CFR 268.7. On the day of shipment, Cannon AFB personnel will perform a final review of the LDR notifications and obtain copies of the notifications to include with the manifest in the facility’s file.

6.8 Wastes Shipped to RCRA Subtitle C Facilities –

Cannon AFB follows the notification and recordkeeping requirements when wastes are shipped off-site to permitted RCRA Subtitle C facilities.

6.9 Waste Generation Records –

The HWAS personnel shall provide the HWP Manager with the waste generation quantities no later than the first Monday of the month for the prior month. The waste generation quantities, in pounds, are available in EESOH-MIS.

6.10 Documentation of Recycling Activities –

Cannon AFB personnel ship certain commodities, such as spent antifreeze and used oil, off-site for recovery. 27 SOCES/CEIE maintains information about the vendors who recycle wastes that are potentially HW. In addition, records of waste analyses that document the classification of wastes shipped off-site for recycling are maintained in 27 SOCES/CEIE records. If a waste is exempt from hazardous waste management because of a regulatory exclusion based on recycling, the Solid Waste Program Manager will maintain records pertaining to the generation, off-site recycling, demonstration that the waste was not speculatively accumulated, and information the vendor provides regarding the recycling process.

6.11 Hazardous Waste Monitor Recordkeeping –

Hazardous Waste Monitors must maintain a Hazardous/Universal Waste Continuity Book that includes the following information:

Signed appointment letters for the Hazardous Waste Monitors, which are updated as personnel change;

Training Records (ESOH-TN (or ADLS or other available CBT equivalent) certificates or documentation from the HWP Manager for instructor-provided training);

Hazardous Materials Authorized User’s List (the list of approved AF Forms 3952 or electronic equivalent in EESOH-MIS can be referenced);

Waste stream characterization information for all processes and applicable forms, including the HWPS, Waste Process Descriptions, and any document revisions;

For hazardous wastes, AF Forms 2005 (or electronic equivalent generated through EESOH-MIS) and container log; and

Copies of waste program evaluations, which may consist of, but not limited to, SAV results, Unit Environmental Coordinator (UEC) guidance, ESOHCAMP assessment findings with corrective actions, and notice of deficiencies or violations issued by either EPA Region VI or the State of New Mexico.

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

7.1.1 Waste Stream Inventory -

The Waste Stream Inventory identifies waste streams and their EPA waste codes that have been characterized at Cannon AFB. Because of the dynamic mission at Cannon AFB, potential exists for the Waste Stream Inventory to change from day-to-day. The current, updated Waste Stream Inventory and location of each waste stream is maintained on eDash in the Hazardous Waste Program area.

The Waste Analysis Plan (WAP) for Cannon AFB, as outlined in Appendix A, describes the procedures used to obtain chemical and physical data on all wastes generated to ensure proper identification.

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

7.2.1 Waste Characterization –

Materials that can no longer be used for their intended purpose in any application must be characterized to determine proper disposal. The generator of the waste is responsible for providing information on the waste stream and a description of the waste-generating process, which is needed to characterize the waste.

The SDSs for materials used in the process are often needed to characterize the waste. The 27 SOCES/CEIE HWP Manager will review information provided to verify that adequate information has been obtained. Key elements of waste characterization include:

Hazardous waste characteristics and listings that are used as the basis for identifying hazardous wastes; and

The waste analysis plan to be used to evaluate Cannon AFB waste streams.

7.2.2 Solid Wastes –

For a waste to be categorized as HW, it must first meet the definition of a solid waste. Solid wastes may be solid, semi-solid, liquid, or a contained gas. Solid wastes include garbage, refuse, sludge, materials that have served their intended purpose, discarded products, and manufacturing by-products. Materials that are intended to be discarded, but have not actually been discarded, may also qualify as HW. This category includes chemicals in storage that are no longer usable and cannot be reclaimed, recycled, or used elsewhere. Certain materials are excluded from the definition of solid waste, and thus are not considered HW, including domestic sewage and point source discharges subject to regulation under the Clean Water Act. Thus, the process for determining which unusable or discarded materials are solid wastes and potentially hazardous wastes is a complex process. Contact the HWP Manager to evaluate specific discarded materials. If the discarded material is not excluded from hazardous waste regulations, it must be evaluated to determine whether it is a listed and/or characteristic HW, as explained below.

This evaluation can be conducted using generator’s knowledge of the waste stream or through analytical testing. The flowchart below describes the process for determining if a waste should be characterized as hazardous.

7.2.3 Listed and Characteristic Hazardous Wastes –

Once a waste is classified as solid waste, a HW determination is made. A waste is regulated as hazardous by characteristic or by listing.

Listed Wastes - A waste is determined to be a hazardous waste if it is specifically listed on one of four lists (the F, K, P and U lists) found in title 40 of the Code of Federal Regulations (CFR) in section 261.

o The F list (non-specific source wastes) - The F list designates as hazardous particular solid wastes from certain industrial or manufacturing processes. Because the processes producing these wastes can occur in different sectors of industry, the F list wastes are known as wastes from non-specific sources. Wastes included on the F list are found in the regulations at 40 CFR § 261.31.

The F list waste codes are divided into seven subgroups of wastes, generally depending on the type of manufacturing or industrial operation that creates them.

The seven sub-groups are:

Spent solvent wastes (F001 - F005) Wastes from electroplating and other metal finishing operations (F006 -

F012, and F019) Dioxin bearing wastes (F020 - F023 and F026 - F028) Wastes from production of certain chlorinated aliphatic hydrocarbons

(F024 and F025) Wastes from wood preserving (F032, F034, and F035) Petroleum refinery wastewater treatment sludges (F037 and F038) Multisource leachate (F039) o The K list (source-specific wastes) - The K list designates particular solid wastes from certain specific industries as hazardous. Wastes included on the K list are found in the regulations at 40 CFR § 261.32. Currently, neither Cannon AFB nor Melrose AFR generate K-listed wastes.

o The P list and the U list (discarded commercial chemical products) - These two lists are similar in that both list as hazardous certain commercial chemical products when they are discarded or intended to be discarded. These listings consist of commercial chemical products having the generic names listed, off-specification products, container residues, and spill residues. The difference is that the chemicals on the P list are identified as acute hazardous wastes and those on the U list are identified as toxic wastes. For a commercial chemical product (CCP) to be considered a U-listed waste, the constituent of concern must be the sole active ingredient. Some chemicals on both lists may also be designated to have other properties. Wastes included on the P and U lists can be found in the regulations at 40 CFR § 261.33.

Characteristic Wastes o D001 (Ignitability): A liquid with a flashpoint of less than or equal to 140° F or oxidizers.

o D002 (Corrosivity): A liquid waste with a pH less than or equal to 2, or greater than or equal to 12.5.

o D003 (Reactivity): A waste that is unstable, capable of detonation, produces toxic gasses when mixed with water or acid, or reacts violently with water.

o D004-D043 (Toxicity Characteristic): Waste that contains toxic chemicals such as heavy metals, pesticides and solvents that could leach into groundwater from landfills if disposed of improperly. Toxicity is measured using the Toxicity Characteristic Leaching Procedure (TCLP). The maximum TCLP concentration for these wastes is listed in the table below. Concentrations greater than these values require the waste to be classified as hazardous.

EPA

Waste Code

Contaminant Regulatory

Level (mg/L)

EPA

Waste Code

Contaminant Regulatory

Level (mg/L)

D004 Arsenic 5.0 D032 Hexachlorobenzene 0.13

D005 Barium 100 D033 Hexachlorobutadiene 0.5

D018 Benzene 0.5 D034 Hexachloroethane 3.0

D006 Cadmium 1.0 D008 Lead 5.0

D019 Carbon tetrachloride 0.5 D013 Lindane 0.4

D020 Chlordane 0.03 D009 Mercury 0.2

D021 Chlorobenzene 100.0 D014 Methoxychlor 10.0

D022 Chloroform 6.0 D035 Methyl ethyl ketone 200.0

D007 Chromium 5.0 D036 Nitrobenzene 2.0

D023 o-Cresol 200.0 D037 Pentrachlorophenol 100.0

D024 m-Cresol 200.0 D038 Pyridine 5.0

D025 p-Cresol 200.0 D010 Selenium 1.0

D026 Cresol 200.0 D011 Silver 5.0

D016 2,4-D 10.0 D039 Tetrachloroethylene 0.5

D027 1,4-Dicholobenzene 7.5 D015 Toxaphene 0.5

D028 1,2- Dichloroethylene

0.5 D040 Trichloroethylene 0.5

D029 1,1- Dichloroethylene

0.7 D041 2,4,5-Trichlorophenol 400.0

D030 2,4-Dinitrotoluene 0.13 D042 2,4,6-Trichlorophenol 2.0

D012 Endrin 0.02 D017 2,4,5-TP (silvex) 1.0

D031 Heptachlor 0.008 D043 Vinyl chloride 0.2

7.2.4 New Waste Streams -

Generators must contact the HWP Manager when a new waste stream is produced or when the process generating waste changes. To the extent possible, wastes should be characterized without sampling and analysis. User knowledge such as SDSs or past analysis of similar waste streams can be used to characterize waste. Further, use of past analysis of similar waste streams should also include an analysis of the processes involved in the generation of the wastes. To request that a sample be taken for analysis, complete the Request Samples for Analyses Template, attached in Appendix C.

When user knowledge does not lead to conclusive waste characterization, the HWP Manager arranges for a sample of the waste to be taken and sent to a certified laboratory for analysis. When collecting the sample, Hazardous Waste personnel will mark the container with the sample date and number. Sampling and analysis should be conducted in accordance with the requirements specified in EPA publication SW- 846, Test Methods for Solid Waste Analysis, and the WAP.

For each process generating waste, the WAP specifies:

The sampling method;

Laboratory methods;

Detection limits;

Reporting limits;

Sample containers;

Sampling techniques;

Holding times; and Quality assurance/quality control procedures.

Hazardous Waste personnel manage requests for waste determination, receive sample results from their contract laboratory, and review data for quality. Environmental Element personnel characterize the waste and send the sample requestor a HWPS containing instructions for proper disposal of the waste along with a copy of the sample results. The Hazardous Waste Monitor must keep a copy of the sample results and the guidance letter in the Hazardous/Universal Waste Continuity Book.

Once the waste is characterized, the HWP Manager or HW Contractor will update the waste inventory list through EESOH-MIS to include the new waste stream. The HWPS associated with the Hazardous Waste Stream Inventory should contain at minimum:

The generating activity’s identity and location;

The unique waste stream number; and The waste characteristics.

7.2.5 Hazardous Waste Profile Sheet (HWPS) –

Once the HW is characterized by either chemical analysis or user knowledge, the HWP Manager or the HW Contractor will complete the Hazardous Waste Profile Sheet. All completed waste profile sheets will be reviewed by the HWP Manager. See Appendix D for a sample HWPS.

A copy of each applicable Hazardous Waste Profile Sheet must be kept in the section’s Hazardous/Universal Waste Continuity Book. HWPSs will be reviewed at least annually, and updated as necessary. The HWPS must also be updated any time a waste stream changes in any way. The Hazardous Waste Monitor must also notify 27 SOCES/CEIE when the waste stream changes.

7.2.6 Waste Process Description –

Once a waste stream has been characterized, the HWP Manager or HW Contractor will give the generating shop a template for the Waste Process Description. The generating shop should fill out the Waste Process Description as thoroughly as possible and request assistance from the HWP Manager or HW…