HAFB_Hazardous_Waste_Management_Plan_2018.pdf

U. S. AIR FORCE HAZARDOUS WASTE MANAGEMENT PLAN

HOLLOMAN AIR FORCE BASE

4/18/2018

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 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, are referenced.

Each section of this plan begins with standard language that addresses AF and Department of Defense (DoD) policy and federal requirements. The standard language is restricted from editing to ensure consistent application across the AF enterprise. Standard language is maintained by the Air Force Civil Engineer Center (AFCEC) designated Subject Matter Expert (SME) for this plan.

Immediately following the standard text are installation-specific sections that address state, local, and installation-specific requirements and processes. Installation sections are maintained and updated by the installation hazardous waste management program manager and/or the AFCEC Installation Support Section (ISS) appointed to support this installation.

This document is optimized to be accessed and viewed electronically on the installation and Air Force eDASH website, 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 – Sample Analysis Plan

Appendix B – HW IAP Manager's Guide

Appendix C – 90-Day Site Contingency Plan

Appendix D – Comprehensive Medical Disposal Plan

Appendix E – DD Form 1348-1A

Appendix F – 90-Day HWAS Weekly Inspection Checklist

Appendix G – IAP Semi-Annual Inspection Checklist

Appendix H – Contact List

DOCUMENT CONTROL

The initial HWMP must be approved and signed by the Installation Commander (at the time of publication) as the legal Hazardous Waste Generator for the EPA ID assigned to this installation.

Thereafter, the plan must be reviewed and approved annually by the Environmental Management System (EMS) Cross Functional Team (CFT) and updates/changes noted below. NOTE: This is not a Wing Contingency Plan and is not governed by installation or Wing plans or readiness format or coordination requirements of AFI 10-401. It is governed by AFI 32-7042, 3.2. Hazardous Waste Management Plan.”

Record of Updates – The HWMP is updated as changes to waste generation and management practices occur, including those driven by changes in applicable regulations and approved by the installation HW Program Manager as the plan OPR.

Record of Updates

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

1 Rearrange appendices, updates in Sample Analysis Plan, training and non-regulated IAP requirement.

4/13/2018 Isamar Nieves-Cancel HW Program Manager

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Record of Annual Review – In accordance with (IAW) AFI 32-7042, Waste Management, this plan is reviewed annually by the EMS CFT. Formatting and administrative changes should be noted in the above record of updates as approved by the EMS CFT Chair and do not require Installation Commander or Environmental Safety and Occupational Health Council (ESOHC) approval. Substantive revisions require coordination and approval by the Installation Commander as determined by the EMS CFT Chair and/or IAW host installation procedures.

Record of EMS CFT Annual Review

Review Date EMS CFT Chair

Notes/Remarks

4/18/2018 Susan M. Misener Click here to enter text.

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Reviewed and Concur

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

The Hazardous Waste Management Plan (HWMP) is provided as an essential tool for all personnel who are involved with hazardous waste (HW) on Holloman Air Force Base (HAFB) in accordance with AFI 32-7042. HAFB’s goal is 100% compliance with federal and state environmental laws. This includes providing a management plan that gives HAFB personnel a clear understanding of responsibilities, processes, and procedures that are essential for proper and effective management of hazardous waste generated on this installation.

HAFB is classified as a large quantity generator of hazardous waste and is permitted to operate a storage facility under the New Mexico Hazardous Waste Act and the Resource Conservation and Recovery Act (RCRA). Hazardous waste generated on HAFB is managed according to the RCRA Hazardous Waste Facility Operating Permit issued by the New Mexico Environment Department (NMED).

2.0 INSTALLATION PROFILE

Installation Profile

Scope of Plan Base-wide Office of Primary Responsibility

(OPR)

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

HW Program Manager Isamar Nieves-Cancel

(575) 572-3931/6648 Isamar.Nieves-Cancel@us.af.mil

Alternate HW Program Manager Steven Jones

(575) 572-3931/6703 Steven.Jones.17@us.af.mil

Emergency contacts Isamar Nieves-Cancel and Steven Jones Waste registration numbers NM6572124422 HW generator status Large Quantity Generator Universal waste handler status Large Quantity Handler of Universal Waste Permitted HW operations N/A 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 90-Day HWAS at Building 149 HW accumulation time limits 90 Days HW generator reporting frequency HAFB provides a waste fee report, a Waste Minimization report, and a Hazardous Waste Management Activity fee for Open Detonation Unit to NMED annually. HAFB 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 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 AFI 32-7042, Waste Management, applicable installation supplements, and 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

Installation Commander –

The installation commander is ultimately responsible for hazardous waste management and compliance.

The Installation Commander shall:

• Ensure that a HWMP is current, available, and followed by personnel;

• Ensure that appropriate HW management practices are emphasized to all HAFB personnel through education and training;

• Sign all HW permit applications, other regulatory binding agreements, and HW manifests as required;

• Ensure proper disposal of all wastes from HAFB;

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

and

• Ensure appropriate use of the standardized Air Force HW system, Enterprise Environmental Safety and Occupational Health Management Information System (EESOH-MIS), to include tracking of waste generation from shop processes, transfer to central accumulation storage, cost, and turn-in for disposal.

Environmental, Safety and Occupational Health Council (ESOHC) –

The ESOHC will support the installation commander to oversee compliance with hazardous waste laws.

The ESOHC is responsible for review and approval of the HWMP.

Hazardous Waste Program Manager (HWPM) –

• Assumes direct responsibility of all HW management activities of HAFB;

• Acts as the POC for questions and issues concerning HW procedures;

• Oversee operations at 90-Day HWAS;

• Ensures compliance of all HW generating facilities with the HWMP and applicable federal and state regulations;

• Assists setup of new IAPs and in completion of waste characterization;

• Trains IAP managers and personnel that handle HW;

• Reviews the HWMP annually to implement more efficient and effective operations;

• Reviews and signs HW manifests;

• Request military munitions Emergency Permit to NMED.

Base Civil Engineer (CE) –

CE has overall management responsibility of HAFB’s environmental program including:

• Oversee HW disposal contracts;

• Ensure the HW management processes are in compliance with all applicable DoD, federal, state;

interstate, and local environmental requirements;

• Act as liaison office for environmental compliance issues with regulatory agencies;

• Establish local procedures;

• Ensure updated management plans;

• Provide technical expertise with regard to waste management;

• Oversee proper programming and recordkeeping procedures;

• Work with AFCEC/CQ to prepare and modify required permits;

• Implement procedures to ensure generators maintain up-to-date waste stream information and profiles;

• Maintain all HW related records through EESOH-MIS;

• Ensure proper disposal of all wastes from HAFB IAW RCRA; and

• Ensure appropriate personnel are adequately trained.

Defense Logistics Agency - Disposition Services (DLA-DS) –

DLA-DS is the DoD hazardous waste disposal agent. The duties of DLA are as follows:

• Provide HW disposal service to HAFB;

• Complete HW manifests;

• Dispose of hazardous property by reutilization, resale, or service contract;

• Maintain all HW documents, land disposal restriction notices, certifications, and correspondence for a minimum of 3 years in accordance with regulatory agency specifications;

• Ensure that DLA-DS facility personnel meet the training requirements of the applicable federal, state, and Air Force laws and regulations;

• Find a recycler or buyer for applicable material turned into DLA; and

• Advise 49 CES/CEIE of any changes in the turn-in document procedures for hazardous wastes.

Disposal Contracts –

HAFB will use the DLA-DS as the DoD HW disposal agent for routinely generated HW or HW from base operations not connected to a specific contract unless there is a compelling reason to use alternative contract disposal or per exemptions.

Host-Tenant Support –

The AF supports the HW disposal needs of both AF and DoD tenants on AF installations. For intra-service support, host AF installations plan for their tenants’ HW disposal needs unless an exception applies.

Tenants must follow all laws and regulations applicable to HAFB as well as HAFB HWMP, and IAW a Host Tenant Agreement, provide input and submit reports that the HWMP requires.

Installation Management Flight –

The Installation Management Flight is responsible for ensuring the hazardous waste management process is in compliance with all federal and state laws.

• Responsible for the overall management of the Hazardous Waste Management Program;

• Serves as the central contact for questions concerning EPA and NMED requirements and regulatory interpretations;

• Provides guidance and oversight to ensure compliance with federal, state, and Air Force laws and regulations relating to hazardous waste management;

• Oversees hazardous waste inspections conducted by the HW Contractor;

• Coordinates hazardous waste classification and regulatory requirements that apply to wastes generated by base activities;

• Programs for hazardous waste disposal funding, and identifies out-year requirements;

• Responsible for the oversight of the 90-day storage facility;

• Updates the HWMP as required;

• Oversees Hazardous Waste Management training;

• Maintains a current listing of IAP managers; and

• Prepares federal, state, and Air Force management reports.

Initial Accumulation Point (IAP) Manager –

• Identifies all new and existing potential hazardous wastes streams, and notify HAZMART for proper waste classification;

• Ensures the IAP is managed in accordance with the IAP Manager’s Guide (attached in Appendix B) and applicable laws and regulations;

• Notifies the Hazardous Waste Program Manager (HWPM) and HAZMART of any changes in hazardous waste activities, including waste stream process modifications, relocation of IAP's, and names of newly assigned IAP managers;

• Completes required turn-in disposal documents (AF Form 2005 can be found in the IAP Manager’s Guide Appendix A-11);

• Maintains a continuity binder as specified in the IAP Manager's Guide;

• Maintains adequate emergency spill response capability, IAP Site-Specific Contingency Plan and personal protective equipment;

• Ensures hazardous waste is properly characterized, segregated, containerized, marked, labeled, stored, and transferred for disposal;

• Completes the required annual training and place the training certificate in IAP binder;

• Trains and supervises workers involved in the handling of HW; and

• Provides IAP appointment letter.

Non-regulated IAP Manager –

• Completes one-time Hazardous Waste Management – Awareness training in e-Dash Learning Management System. Contact HWPM for additional information about training;

• Provides appointment letter; and

• Maintains a continuity binder as specified in the IAP Manager’s Guide (Appendix B);

o Tab A – Appointment letter o Tab B – Training certificate o Tab C – Hazardous Waste Management Plan o Tab D – Process flow diagram, waste profile and supporting documentation o Tab E – Not applicable o Tab F – Guidance or policy letter o Tab H – Miscellaneous information

90-Day Hazardous Waste Accumulation Site (HWAS) Management –

• Consolidate compatible wastes to the greatest extent possible within regulatory limits;

• Segregate and mark non-compatible wastes;

• Maintain stream of used oil and off-spec fuel into appropriate container;

• Follow turn-in procedures and update EESOH-MIS with items turned into 90-Day site;

• Perform weekly inspections of all containers in 90-Day site;

• Test communications equipment, alarm system, fire protection equipment, etc. monthly;

• Maintain a readily available copy of the site contingency plan (Appendix C);

• Ensure all containers are in compliance with appropriate requirements prior to shipping;

• Ensure proper house-keeping of the 90-Day site;

• Maintain supply of empty containers for waste collection at shops and IAPs;

• Inspect and return empty used containers to the usable container inventory where appropriate;

• Prepares federal, state, and Air Force management reports;

• Ensure copies of the Hazardous Waste Profile Sheets, HWMP, Hazardous Waste Stream

Inventories, and Hazardous Waste Sampling Laboratory Analysis are maintained through EESOH-MIS; and

• Perform all tasks designated via the Fence 2 Fence Contract.

Hazardous Waste Same Day Turn-In –

• Some generating shops may be required to turn in HW the same day it is generated; and

• Universal waste, which includes aerosol cans, broken lamps, batteries, etc., must be turned in to

90-Day HWAS and/or HAZMART the same day as it is no longer in service.

Explosive Ordnance Disposal (EOD) –

• Notifies the HWPM and/or 49 CES/CEIE of required NMED Emergency Permit request.

Contractor –

Contractors performing work at HAFB are responsible for proper management and disposal of HW in accordance with federal and state regulations, as well as the provisions of their contract. HAFB is a large quantity generator of hazardous waste, and all hazardous waste generated at HAFB must be disposed of under the base’s EPA ID number, unless other arrangements have been made through the HWPM.

• Coordinate with the HWPM prior to generating the waste;

• Characterize waste including laboratory analysis when necessary;

• Label waste and store in containers that are approved by the Department of Transportation

(DOT); and

• Ensure all hazardous waste transported offsite for disposal is accompanied by a hazardous waste manifest signed by a qualified individual appointed to do so in writing by the base commander.

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.

HW Managers require specific training to include HW Management Compliance Training and Department of Transportation training to sign HW manifests. Consistent with the training matrix available through eDASH, Installation HW Mangers should complete the following in-residence courses (or equivalent): AFIT 521, Hazardous Waste Management; and DLA - DCPSO00510, Transportation of Hazardous Material/Hazardous Waste (ISEERB approved). Installations will enter procedures regarding site-specific training requirements below based upon Federal, State, and local regulations, consistent with the training matrix available through eDASH.

Installation Supplement – Training

Initial Training –

Initial training must take place within three months of an employee’s arrival or assignment to hazardous waste duties. Employees may only handle hazardous waste under the supervision of a trained individual until they have received the appropriate training.

Trainees will receive a certificate upon completion of the training.

Primary/Alternate IAP managers and their supervisors must receive training from the HWPM.

Annual Training –

All personnel whose duties include working with hazardous waste must complete annual hazardous waste training. The intervals between training must not exceed one year. Training is available from online courses.

• The Hazardous Waste Accumulation Seminar (WESS010) conducted by the Air Force Institute of Technology (AFIT) is offered several times a year.

• The Hazardous Waste Management – Awareness course is offered by the eDash learning Management System. This course is available 24 hours a day.

Contact the HWPM for further information about initial or annual training.

Training Elements –

Hazardous waste training covers the following elements:

• Introduction to the Resource Conservation and Recovery Act (RCRA);

• Hazardous Waste Identification;

• Container Use, Marking, and Labeling;

• Hazardous Waste Turn-in Procedures;

• Hazardous Waste Manifesting and Transportation;

• Spill Prevention and Response;

• Personnel Safety and Training;

• Waste Reduction;

• Recordkeeping and Reporting Requirements;

• Universal Wastes; and

• Specific Wastes.

Training Recordkeeping –

Training certificates and records must be kept for 3 years from the date the individual last worked at HAFB HW generating shop. The records and certificates must be readily available for inspection. At minimum, the training records must include:

• Student’s name;

• Job title;

• Job description;

• Previous HW training;

• Dates of training;

• Instructor’s name; and

• Date of annual refresher course.

6.0 RECORDKEEPING AND REPORTING

Recordkeeping

The installation complies with the following U.S. Federal HW recordkeeping requirements as applicable based on generator status.

Summary of HW Recordkeeping Requirements

Record* Citation Retention Time** Citation HW determination documentation

40 CFR 262.11(f) 3 years from the date that the waste was last sent to a TSDF

40 CFR 262.11(f)

HW Biennial/Annual Report

40 CFR 262.41 3 years from the due date of the report 40 CFR 262.40(b)

HW manifest 40 CFR 262.20 3 years from the day the waste was accepted by the initial transporter

40 CFR 262.40(a)

Small Qty HWAS inspection logs

40 CFR

262.16(b)(2)(iv)

Although records are not formally required, the best management practice is to record and retain for 3 years to demonstrate compliance

N/A

Large Qty HWAS inspection logs

40 CFR

262.17(a)(1)(v) 40 CFR 264.15(d) 40 CFR 265.15(d)

For interim and permitted operations, 3 years from the date the inspection was conducted.

For all other LQGs, the best management practice is to retain for 3 years to demonstrate compliance

40 CFR 265.14(d) 40 CFR 265.15(d)

Preparedness and prevention arrangements with local authorities

40 CFR

262.16(b)(8)(vi)(B)

The federal regulations do not offer a minimum retention time, but the best management practice is to retain the plan while active and for 3 years thereafter to demonstrate compliance

N/A

Consolidation of hazardous waste received from very small quantity generators.

40 CFR 262.17(f) 3 years from the date the hazardous waste was received from the very small quantity generator

40 CFR 262.17(f)

Exception reports 40 CFR 262.42 3 years from the due date of the report 40 CFR 262.40(b) Land restricted waste determination

40 CFR 268.7(a)(1) 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(a)(8)

Land restriction notice and certification

40 CFR 268.7(a)(2) 3 years from the date the waste was last sent to a TSDF

40 CFR 268.7(a)(8)

Notification of intent to export waste

40 CFR 262.83(b) 3 years from the date the HW was accepted by the initial transporter

40 CFR

262.83(i)(1)(i)

Waste export confirmation of receipt and exception reports

40 CFR 262.83(h) 3 years from the date the HW was accepted by the initial transporter

40 CFR

262.83(i)(1)(iii)

Annual report (required of primary exporters of HW)

40 CFR 262.83(g) 3 years from the date the HW was accepted by the initial transporter

40 CFR

262.83(i)(1)(ii)

Record* Citation Retention Time** Citation Employee training records (including appointment letters for key HW personnel)

40 CFR

262.16(b)(9)(iii)

40 CFR

262.17(a)(7)(iv) 40 CFR 264.16(d) 40 CFR 265.16(d)

For interim and permitted operations- current personnel: until closure of the site; Former personnel: 3 years from date the individual last worked there. For all other LQGs and SQGs, the best management practice is to retain for 3 years to demonstrate compliance

40 CFR

262.17(a)(7)(iv) 40 CFR 264.16(e) 40 CFR 265.16(e)

*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

Recordkeeping –

The facility permits are the responsibility of the Installation Commander. HAFB will track HW with the EPA HW manifest and report HW management activities using EESOH-MIS. HW-related reports, documents, studies, HW manifests, and disposal records (including contracts) will be destroyed 50 years from the date of the record.

Reporting to NMED -

• 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 HWPM shall oversee the submittal and maintenance of the records, and shall make them available to appropriate state and federal inspectors upon request.

• Annual Hazardous Waste Fee Report – o IAW with 20 NMAC 4.3, HAFB pays hazardous waste generation fees by August 1 to

NMED annually. 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, HAFB is required to pay a set annual business fee based on its status as a large quantity generator.

• Annual Waste Minimization Report – o HAFB will submit a certified plan annually by December 1 to NMED for the previous year ending September 30th, which states that Holloman AFB has a program in place to reduce the volume and toxicity of all hazardous wastes which are generated by the facility to the degree determined to be economically practicable. The report also contains the proposed method of treatment, storage, or disposal that is practicable and currently available which minimizes the present and future threat to human health and the environment.

• Hazardous Waste Management Activity Fee for the Open Detonation Unit (ODU) — o IAW NMAC 20.4.2.211, the annual Hazardous Waste Management Activity Fee for the

ODU shall be waived for hazardous waste management units for which the owner or operator provides documentation to NMED that hazardous waste management activities did not occur at the unit during the previous calendar year. Currently, the HAFB ODU is in the process of closure and is requesting a waiver every year.

• Biennial Hazardous Waste Report – o HAFB ships hazardous waste off-site to a TSDF facility within the US and must prepare and submit a Biannual Report to NMED by March 1 of each even-numbered year. This report covers generator activities from the previous two years. The report includes:

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 hazardous waste shipped off-site;

A description of the efforts undertaken by HAFB 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.

• Additional Reports – o IAW with 40 CFR 264.77, HAFB must submit reports of releases, fires, and explosions that require the implementation of the contingency plan.

IAP Recordkeeping and Reporting –

• Waste Stream Log Book – Each IAP must maintain a waste stream log book. A separate log book will be maintained for each waste stream. The Log Book must be readily available for inspection and maintained for 3 years. A new entry will be made in the log book each time waste is added to the container, and will contain the following items:

o Name of person adding the waste;

o Estimated quantity added; and o Date waste added.

• IAP Binder – IAP managers will establish and maintain a continuity binder. The IAP binder must be complete and readily available for inspection. All documentation must be maintained for three years. The IAP binder will contain the following items:

o Letter of Appointment;

o HW job description;

o HW training requirements;

o HW training certificates;

o HWMP;

o Process flow chart for each waste stream;

o HW Profile Sheets with attached Laboratory Results and/or SDSs;

o Spill response equipment inventory list;

o Site Specific Contingency Plan;

o Weekly inspection checklists; and o Policy letters and guidance memos.

90-Day HWAS Reporting –

The 90-Day personnel will maintain a weekly container report with information on the HW containers currently in the 90-Day HWAS. The report will be sent to the DLA and to 49 CES Environmental on a weekly basis. The report will contain the following information about the containers in the 90-Day

HWAS:

• Generating organization of waste;

• Accumulation start date (date 55 gallon limit reached);

• Container Number; and

• Waste profile of each waste.

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

Obtaining a Copy of the Waste Inventory -

HAFB personnel are able to obtain a copy of the most updated waste inventory by contacting the HWPM or the 90-Day Accumulation Site Manager.

New Waste Streams -

Generators must contact the HWPM 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.

When user knowledge does not lead to conclusive waste characterization, the HWPM arranges for a sample of the waste to be taken and sent to a certified laboratory for analysis in accordance with the HAFB Sampling and Analysis Plan (SAP). The HAFB SAP is attached as Appendix A.

For each process generating waste, the SAP specifies:

• The sampling method;

• Laboratory methods;

• Detection limits;

• Reporting limits;

• Sample containers;

• Sampling techniques;

• Holding times; and

• Quality assurance/quality control procedures.

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) found in Appendix A.

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

Hazardous Waste Classification –

A waste must be first characterized as a “Solid Waste” before being characterized as a hazardous waste.

Solid waste is any discarded solid, compressed gas, or liquid material other than domestic sewage.

“Discarded” includes abandoned, recycled or inherently waste-like hazardous materials. Once a waste is classified as solid waste, a hazardous waste 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 nonspecific 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 subgroups are:

• Spent solvent wastes (F001 - F005)

• Heavy metal and cyanide waste 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, HAFB does not 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 species, 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. 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 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.

Waste Profile Sheet –

Once the HW is characterized by either chemical analysis or user knowledge, the HWPM or the HW Contractor will complete the Hazardous Waste Profile Sheet. All completed waste profile sheets will be reviewed by the HWPM.

A copy of each applicable Hazardous Waste Profile Sheet must be kept in the IAP binder. The Hazardous Waste Profile Sheet will be reviewed and updated, if needed, at minimum once per year. The Waste Profile Sheet must also be updated any time a waste stream changes in any way. The IAP manager must also notify 49 CES Environmental or HAZMART when the waste stream changes. See IAP Manager’s Guide (Appendix A-6 for an example of the Hazardous Waste Profile Sheet.

Military Munitions –

Used or fired military munitions are solid wastes and potentially hazardous waste when they are removed from their landing spot and managed off range (i.e. when transported off-range and stored, reclaimed, treated, or disposed of (buried or landfilled)) on range.

When munitions are determined by assessors to be unserviceable, AF Form 191 is completed describing the quantity and condition of the item and forwarded to Hill AFB, Utah. Item managers determine if the munitions can be reused elsewhere in the Air Force and if a requirement is identified, the form is returned to Holloman AFB with the necessary shipping instructions. If a reuse cannot be identified within the Air Force, the munitions items will be shipped back to the Army for further assessment, testing, and/or analysis to determine if the items can be reused or recycled by other DoD agencies or sold through the foreign military sales program. If the munition is unsaved for transport, an Emergency Permit will need to be requested from NMED to have the munition destroyed at the EOD training range when possible.

EOD personnel will request the Emergency Permit to 49 CES/CEIE. The Emergency Permit is completed and submitted to NMED by 49 CES/CEIE. Munitions which have been used on Holloman’s range will not be removed from any range without first being rendered safe and certified by EOD personnel that the item is safe to handle.

Mixed Waste (MW) –

MW consists of waste containing both HW and radioactive material. The Air Force Safety Center (AFSC) provides 91b policy under AFI 91-108, Air Force Nuclear Weapons Intrinsic Radiation and 91B Radioactive Material Safety Program. Consult AFI 40-201, Managing Radioactive Material in the US Air Force, for MW disposal requirements not related to nuclear weapons maintenance.

Unknown Wastes –

Unknown wastes that exceed 55 gallons should be placed in the 90-Day facility and be readied for sampling and analysis. Unknown wastes less than 55 gallons will remain at the IAP at the HWPM’s discretion.

7.3 Container Management

Container management procedures are as follows:

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

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

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

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

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

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

Installation Supplement – Container Management

New Container Management -

Upon the establishment of a new waste stream, the HW Contractor will decide the type of DOT-approved container required based upon the waste characterization. Waste streams can be characterized through generator knowledge or by sample and analysis, if necessary. Shop personnel can obtain information on the type of containers used at the individual IAPs through EESOH-MIS.

The 90-Day personnel shall maintain a supply of empty containers for waste collection for HAZMART and IAPs. The base 49 CES Environmental or HW Contractor will provide the new containers.

Containers in Use –

Containers that have been placed into service must be labeled in accordance with the IAP Manager’s Guide (See Appendix B). Once the 55 gallon limit is reached the container must be transferred to the 90- Day HWAS. The generating organization is required to call the 90-Day personnel for a HW pick-up when the 55 gallon (or 1 quart acutely hazardous) limit is reached.

Transfer of the HW to the 90-Day HWAS requires the generating organization to provide a current waste profile sheet, along with two completed copies of the AF Form 2005. The IAP manager will provide one copy of the AF Form 2005 that will be kept for recordkeeping, and one copy will be given to the 90-Day personnel. Federal law requires the waste to be moved to the 90-Day HWAS within three days of reaching the 55 gallon (or 1 quart acutely hazardous) limit. 90-Day personnel will bring an empty, labeled container to replace the container being picked-up at the IAP.

After the 90-Day personnel brings the HW containers from the IAP to the HWAS, 90-Day personnel will update information in EESOH-MIS. The accumulation start date must be placed on the container label.

For HW streams, the accumulation start date begins once the container is full and/or transferred to the 90- Day HWAS.

Handling and Storing Liquid and Solid Waste -

The following lists explain the general procedures of storing and handling liquid and solid waste in containers:

• Liquid Waste – o Wear proper PPE;

o Use funnels when adding wastes to the containers;

o Add waste carefully and slowly;

o Containers will remain securely closed at all times except when adding wastes;

o Container lid/funnel must form a seal;

o Containers will not be filled beyond 90% capacity; 10% airspace will be maintained to allow for waste expansion; and o Liquid waste containers must be located on a spill pallet.

• Solid Waste – o Wear proper PPE;

o Ensure that no free liquid is stored in the container;

o Containers will remain securely closed at all times except when adding wastes;

o Containers will be filled to maximum capacity; and o Mechanical compression is not allowed for HW streams in IAP’s.

Container Spills –

In the event of a HW spill, personnel should respond accordingly to comply with the 90-Day HWAS Contingency Plan, the IAP Site-Specific Contingency Plan, or the HAFB SPCC Plan, as applicable.

Empty Containers –

Empty containers that previously held hazardous materials will be collected and recycled if they are “RCRA empty.” Containers are considered empty if they satisfy one of the following criteria depending on the container:

• No more than 2.5 centimeters (1 inch) of residue remains on the bottom of the container or inner liner;

• No more than 3% by weight of the total capacity of the container remains in the container or the inner liner if the container is less than or equal to 119 gallons in size;

• No more than 0.3% by weight of the total capacity of the container remains in the container or inner liner if the container is greater than 119 gallons in size.

All wastes must be removed from the containers by either pouring, pumping, and/or scraping. Excess material should be turned in based on the IAP Turn-in Requirements. Non-metal containers that are “RCRA empty” may be disposed of in the normal trash. All labels identifying HAFB must be removed and destroyed.

Recycling empty containers is the preferred method of managing empty metal containers and should be employed whenever the opportunity exists. 90-Day personnel will inspect and return all empty used containers to the usable container inventory where appropriate. Coordination should be made with the HWPM for appropriate location of recycling disposition.

Containers With P-listed Waste –

Containers that previously held P-listed or “acutely hazardous” waste have special requirements.

Containers holding P-listed wastes have a maximum volume limit of one quart. HAFB generates P-listed wastes from waste pharmaceuticals. A Comprehensive Medical Disposal Plan is available in Appendix D

7.4. Labeling and Marking

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

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

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

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

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

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

• Generator’s name and address

• Generator’s EPA Identification Number

• Manifest tracking

These markings are:

• Durable

• In English, and/or appropriate host nation language

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

• Unobscured by labels or other attachments

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

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

• UW batteries must be labeled with any one of the following phrases: “Universal Waste- Battery(ies),” or “Waste Battery(ies),” or “Used Battery(ies)

• UW thermostats must be labeled with any of the following phrases: “Universal Waste-Mercury Thermostat(s),” “Waste Mercury Thermostat(s),” or “Used Mercury Thermostat(s)

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

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

Installation Supplement – Labeling and Marking

Labeling and Marking Containers -

The following lists explain the general procedures for labeling hazardous and non-hazardous waste containers in an IAP shop. The HW Contractor will provide the appropriate hazardous placards and HW labels.

Hazardous Waste Containers -

• Upon receiving the empty, labeled container from the 90-Day personnel, the generating organization, office symbol, and full telephone number will be placed on the bottom third of the container. See Appendix A-9 of the IAP Manager’s Guide.

• The Drum Tracking Number will be placed on the bottom third of the container, directly under the generating organization information. This number is assigned by EESOH-MIS.

• Example EESOH-MIS container number: 806201600099. See Appendix A-9 of the IAP Manager’s Guide.

• The Accumulation Start Date shall be placed on the label only after the drum is full and is transferred to the 90-Day facility. See Appendices A-9 and A-10 of the IAP Manager’s Guide.

Non-Hazardous Waste Containers -

• Apply the same Hazardous Waste Containers rules mentioned above with the exception of having a Hazardous Waste warning label.

• A hazard class label is not required if the waste is not a hazardous material.

• The generating organization, office symbol, and full telephone number (including area code) placed on the bottom third of container. See Appendix A-9 of the IAP Manager’s Guide.

• The Drum Tracking Number will be placed on the bottom third of the container, directly under the generating organization information. This number is assigned by EESOH-MIS.

• Example EESOH-MIS container number: 806201600099. See Appendix A-9 of the IAP

Manager’s Guide.

7.5 Accumulation Area Management

Accumulation area management procedures are as follows:

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

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

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

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

Installation Supplement – Accumulation Area Management

Initial Accumulation Points (IAP) –

An IAP is a specific area where waste that is routinely generated is initially accumulated under the control of a trained IAP manager of the shop generating the waste. Each IAP must also be assigned a primary and alternate site manager. IAPs must be located at or near the point of generation of the waste. HAFB will strive to maintain the minimal number of IAPs and HWAS necessary to perform their mission and meet regulatory requirements.

IAP Accumulation Threshold -

IAPs will be managed in accordance with the IAP Manager's Guide. While IAPs have a limit on quantity of 55 gallons or 1 quart of acutely hazardous waste each per IAP. IAPs have no time limits that apply to HW storage time until the accumulation volume limit has been reached.

Storing HW at an IAP -

Generators must accumulate hazardous waste in DOT-approved containers. Containers that have been placed into service must be labeled in accordance with the IAP Manager’s Guide. The following items must also be considered when storing HW at an IAP:

• Incompatible HW must not be stored in the same area.

• HW containers outdoors holding liquid must have secondary containment with 110%…