HWMP_Template_-_CONUS_Final_20180117.docx

HAZARDOUS WASTE MANAGEMENT PLAN

U. S. AIR FORCE HAZARDOUS WASTE MANAGEMENT PLAN

Installation Name Installation Shield Approval Date

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

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

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

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 (Incorporate installation-specific content)

2.0 INSTALLATION PROFILE

Installation Profile

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 Incorporate installation-specific content

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 Incorporate installation-specific content

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

40 CFR 264.15(d) 40 CFR 265.15(d)

40 CFR 265.15(d)

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

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 Incorporate installation-specific content

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 Incorporate installation-specific content. The installation must include directions on how personnel can obtain a copy of the waste inventory and how a new waste stream is managed by shop personnel.

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 Incorporate installation-specific content

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 Incorporate installation-specific content

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:

· The words “Hazardous Waste”

· A description of the contents of the container

· 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 Incorporate installation-specific content

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 Incorporate installation-specific content

7.6 Transportation

The HW Manager has overall responsibility for the transportation of HW from an IAP to an HWAS, and from an HWAS to the disposal facility. The HW Manager ensures:

· All transportation over public highways is conducted IAW applicable DOT requirements.

· Containers are DOT approved.

· Transporters have the appropriate training.

· Uniform Hazardous Waste Manifest are prepared for offsite transportation.

· All necessary documentation has been completed and records are maintained IAW all applicable federal, state, local and FGS requirements and the AF Records Disposition Schedule.

Installation Supplement – Transportation Incorporate installation-specific content

7.7 Turn In/Disposal

The turn in procedures contained in DoD 4160.12-M. DLA Disposition Services are followed. In the event an alternate route for disposal is needed, a waiver will be obtained with proper justification and approval.

Containers are inspected, prior to turn-in, to ensure that container management procedures have been followed and that containers are properly labeled and in good condition. If the container is not in good condition, contents are transferred to a container that is in good condition.

Installation Supplement – Turn In/Disposal Incorporate installation-specific content

7.8 Inspection

Inspection processes fulfill the “Check” function of the EMS “Plan, Do, Check, Act” cycle. HWASs are inspected at least weekly to ensure proper accumulation and container management. RCRA Part B permitted storage facilities are inspected according to the inspection schedule established in the permit. All other inspections occur IAW AFI 90-201, The Air Force Inspection System and the Commander’s Self Inspection Program. Inspection records are maintained IAW the Recordkeeping and Reporting section of this plan.

Installation Supplement – Inspection Incorporate installation-specific content

7.9 Waste Minimization

HW manifests include certification that a waste minimization program is in place. Below are key activities and processes that are performed as part of waste minimization and pollution prevention efforts:

· Hazardous material process authorization and hazardous materials management processes –Each process involving use of hazardous materials and generation of waste streams is evaluated and authorized. Process authorization is performed through EESOH-MIS. The HW Manager, HMMP Team and the generating activity make a final determination whether or not the results of the process authorization effort are sufficient to reduce waste toxicity and volume

· Procurement and use of minimal quantities – When a material with environmental risk must be used, minimal quantities are procured to minimize surplus quantities and shelf life exceedances

· Recycling – When the use of hazardous materials is unavoidable, excess or waste material is evaluated for reuse or recycling

· Environmental action planning – Environmental action plans (EAPs) are developed and maintained as part of the overall EMS. EAPs are management plans that translate environmental objectives and targets into actionable plans. Waste minimization efforts are considered during development of EAPs Installation Supplement – Waste Minimization Incorporate installation-specific content

7.10 Preparedness and Prevention

Preparedness and prevention practices are described in emergency prevention and response plans available through the references section of this plan and are maintained IAW the EMS on eDASH: Emergency Preparedness and Response, and shall include the Installation Spill Prevention, Control, and Countermeasure (SPCC) Plan (or equivalent) or a specific Hazardous Waste Contingency Plan.

Installation Supplement – Preparedness and Prevention Incorporate installation-specific content

7.11 Waste Specific Procedures

Waste-specific procedures are included in the installation supplement below or maintained as separate operational controls outside of this plan.

Installation Supplement – Waste Specific Procedures Incorporate installation-specific content

8.0 REFERENCES

Standard References (Applicable to all AF Installations)

· ADLS – Advanced Distributed Learning Service

· AFI 32-7001, Environmental Management

· AFI 32-7042, Waste Management

· AFI 32-7086, Hazardous Materials Management

· AFI 90-201, The Air Force Inspection System

· AFLOA HW Legal and Other Requirements – The Air Force Legal Operations Authority (AFLOA) legal registry lists and provides access to federal (e.g., CFR, U.S. Code), DoD, AF and other legal requirements

· ARCNet – Training resource for Air Force Reserve Command

· DoD 4160.21 (all volumes), Defense Materiel Disposition

· EASI Database (includes SIRIS)

· eDASH Environmental Action Plan (EAP)

· eDASH Hazardous Waste Home Page

· eDASH Hazardous Waste Training Matrix

· EESOH-MIS Software Module

· Environmental, Safety & Occupational Health Training Network (ESOH-TN)

· Hazardous Waste Playbook Installation References AF Form 2005

9.0 ACRONYMS

Standard Acronyms (Applicable to all AF Installations)

· eDASH Acronym Library

· Hazardous Waste Playbook – Acronym Section

· U.S. EPA Terms & Acronyms Installation Acronyms Incorporate installation-specific content

10.0 DEFINITIONS

Standard Definitions (Applicable to all AF Installations)

· Hazardous Waste Playbook – Definitions Section

· Installation Definitions Incorporate installation-specific content

11.0 INSTALLATION-SPECIFIC CONTENT

Incorporate installation-specific content

APPENDICES

Appendix A – Waste Analysis Plan