JA 04. FTQW 23-1401 Hazardous Waste Management Plan, 2024.pdf

Department of the Air Force

Hazardous Waste Management Plan

Eielson

Installation Supplement

About This Plan

Document Control

HWMP Approval (Signature Page)

1 Overview and Scope

2 Installation Profile

3 Environmental Management System

4 Roles and Responsibilities

5 Training

6 Recordkeeping and Reporting

7 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/HW Recycling

7.10 Preparedness and Prevention

7.11 Waste Specific Procedures

8 References

9 Acronyms

10 Definitions

11 Installation-Specific Content

ABOUT THIS PLAN

This installation-specific Environmental Management Plan (EMP) uses 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 and associated document links, including Air Force Instructions (AFIs); Air Force Manuals (AFMANs); AF Playbooks; and federal, state, local, and permit requirements, are referenced to ensure current content.

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 HW Program Manager and/or the AFCEC Section appointed to support this installation.

This document is optimized to be accessed and viewed electronically on the installation and AF eDASH website, the primary communication tool for AF EMPs.

DOCUMENT CONTROL

Standardized HWMP Template

In accordance with (IAW) the AFCEC Environmental (CZ) Business Rule (BR) 08, EMP Review, Update, and Maintenance, the standard content in this HWMP template is reviewed periodically, updated as appropriate, and approved by the HW SME.

This version of the template is current as of 06/05/2020 and supersedes the 2018 version.

NOTE: When installations update their HWMPs, installations should adopt the most recent version of this template available. Installations are not required to change HWMPs after template updates.

Installation HWMP

The initial HWMP must be approved and signed by the Installation Commander (at the time of publication) as the legal HW Generator for the Environmental Protection Agency (EPA) ID assigned to this installation. The approval can be via signature or as documented in appropriate Environment, Safety, and Occupational Health Council (ESOHC) minutes (AFMAN 32-7002, 3.2.2.). 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, Air Force Operations Planning and Execution. It is governed by AFMAN 32-7002, Environmental Compliance and Pollution Prevention, Section 5.2. Hazardous Waste Management Plan (HWMP). Because this is not a contingency plan, coordination should be with EMS CFT and applicable units with roles and responsibilities in the HWMP. The plan does not require a new signature after each change in wing command.

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 Office of Primary Responsibility (OPR). Formatting and administrative changes such as the incorporation of updated regulatory language, or other minor updates are documented below.

Record of Annual Review – IAW AFMAN 32-7002, this plan is reviewed annually by the EMS CFT. Formatting and administrative changes should be noted in the previous paragraph for 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. Substantive changes include manpower or resource requirements changes that impact installation hazardous waste generating organizations.

Installation Supplement

Record of Updates

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

1 Plan updated to Air Force standardized format.

October 29, 2019

2 Plan revised with installation-specific comments and updates

November 20, 2020

3 Plan revised to include updated Shop Hazardous Waste Binder contents, language stating records are kept in EESOH-MIS. Added Aerosol cans to UW and added waste specific procedures to comply with AFMAN 32-7002. Updated labeling section and roles and responsibilities. Updated Appendices including WAP, Inspection Checklists, Procedure Letters, Shop SOI template, Quick Reference Guide Template, Example Labels, Facility Map, and Waste Site Waste Stream List.

May 12, 4 Removed MISC designation of shops, updated language for Hazardous materials and waste pharmaceuticals. Added language to include inspections for UW sites and construction sites. Updated SAP list.

Dec 21, 5 Updated contact info and SOI template Dec 15, Record of EMS CFT Annual Review

Review Date EMS CFT Chair Notes/Remarks 12/21/2022 Briefed at 2022 DEC CFT meeting Changes Briefed at 2022 DEC CFR meeting 12/15/2023 Briefed at 2023 DEC CFT meeting Changes Briefed at 2023 DEC CFR meeting 8/8/2024 Briefed at Q3 CFT, changes approved via signature at July ESOHC See signed July 2024 ESOHC meeting minutes

HWMP APPROVAL (SIGNATURE PAGE)

Installation Supplement

Plan approved in ESOHC meeting minutes received on 8 August 2024, see documentation in the meeting minutes at the following link :

https://usaf.dps.mil/teams/10626/Eielson/WPP/EMSPage/Management%20Review.aspx

Digital Signature

KORNOWSKE, JOSEPH CIV USAF PACAF 354 CES/CEIE KORNOWSKE, JOSEPH CIV USAF PACAF 354 CES/CEIE Date: 08/12/2024 1:16:52 pm

KORNOWSKE, JOSEPH CIV USAF PACAF 354 CES/CEIE

1 OVERVIEW AND SCOPE

This HWMP contains procedures for management of HW. In lieu of federal, or state requirements, AFMAN 32-7002, acts as the main driver for the HWMP. The HW Playbook serves as supplemental guidance to this plan. Where applicable, DoD, AF, and Federal Resource Conservation and Recovery Act (RCRA) requirements are included. Each installation must include supplements as warranted to address applicable State and/or local HW requirements/procedures.

This HWMP provides Eielson Air Force Base (AFB) with a plan which addresses the mandatory HW management requirements of the EPA and AF. It covers the control and management of hazardous materials (HMs) from the point they become waste to the point of final disposition. This instruction does not cover radioactive, medical/ biological, munitions, CERCLA, wastes which are regulated under separate guidance. This instruction does cover radioactive wastes of "Low Level Mixed Waste" (LLMW). LLMW RCRA definition;

waste that contains both low-level radioactive waste and RCRA hazardous waste. Please coordinate with Bioenvironmental Engineering (BE) and the Radiation Safety Officer (RSO) regarding the disposal of medical or radioactive waste. Please coordinate with the HW program manager regarding the disposal of CERCLA waste. Please coordinate with HW program manager regarding the disposal of munitions waste. All munitions management shall comply with 40 CFR 266, Subpart M.

This HWMP provides a framework for complying with environmental standards applicable to HW, universal waste (UW), and used oil at Eielson AFB. It is designed to provide the Installation Commander with the appropriate level of confidence that Eielson AFB is operating in accordance with the requirements of the applicable HW regulations. Use the procedures in this plan to comply with applicable federal, local, state, and AF regulations for HW, UW, non-hazardous waste, and used oil management.

The installation commander 354th Fighter Wing Commander (354 FW/CC), through subordinate commanders, is responsible for installation compliance with HW management and disposal laws and regulations. Disposal of HW by the waste disposal contractor or Defense Logistics Agency (DLA) Disposition Services does not relieve the installation commander of this obligation.

This HWMP applies to all organizations (host, tenant units, visiting units, contractors and personnel, but not residential households) that generate HW, UW, non-hazardous waste, and used oil within the jurisdiction of Eielson AFB. It is designed to help designate which shops are Satellite Accumulation Points (SAPs), Central Accumulation Areas (CAAs) (also referred to as Accumulation Points (APs), and Universal Waste Points (UW) and identify alternative materials for use to reduce or eliminate the volume of waste generated.

354 CES/CEIE provides technical assistance to all base activities regarding proper management of HW, non-hazardous waste, UW, and used oil to ensure compliance with federal, local, state and AF regulations. 354 CES/CEIE is the single point of contact to the EPA for all issues regarding HW, UW, and used oil on Eielson AFB. Please see the Integrated Solid Waste Management Plan for guidance on management of solid waste.

Any deficiencies or inaccuracies noted in this plan or difficulties complying with this instruction or any HW law or regulation must be reported to 354 CES/CEIE. Questions regarding this plan can be directed to the base Hazardous Waste Program Manager at (907) 377-4017.

2 INSTALLATION PROFILE

Installation Supplement

Installation Profile

Scope of Plan Units and activities assigned to Eielson AFB (354th Fighter Wing , Operations Group, Maintenance group, Mission Support Group, Medical Group), 1st Air Support Operations Group, onsite contractors and tenant units [168th Air Refueling Wing and Det. 1, 210th Rescue Squadron (Alaska Air National Guard), Detachment 460 (Air Force Technical Applications Center), Arctic Survival School, Detachment 1 (66th Training Squadron), Detachment. 632 (Air Force Office of Special Investigations), Detachment 25 (372nd Training Squadron), Army and Air Force Exchange Service (AAFES) and Defense Commissary Agency (DeCA)

OPR (Civil Engineer or other designated office) 354 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 Joseph Kornowske, 354 CES/CEIEC Alternate HW Program Manager Emilio Avila, 354 CES/CEIEC Hazardous Waste Facility Manager Enzo Fochesatto, 354 CES/CEIEC

Emergency contacts 911 Note: When dialing 911 from a cell phone the caller must immediately identify they are reporting an emergency for Eielson AFB. The Fairbanks North Star Borough 911 Center will transfer the call to Eielson AFB Fire Dispatch

Waste registration numbers EPA Generator ID Number: AK1570028646 HW generator status Large Quantity Generator Universal waste handler status Small Quantity Handler Permitted HW operations Not Applicable Federal regulatory references RCRA (40 CFR 260-279), TSCA (40 CFR 761/763), CWA (40 CFR 112), EPCRA/CERCLA (40 CFR 355), DOT (49 CFR 172-177), OSHA (29 CFR 1910 )

State and local regulatory agencies

Alaska Department of Environmental Conservation

State and local regulatory references

Alaska Administrative Code (AAC), Chapter 18:

Solid Waste Management (18 AAC 60), Hazardous Waste (18 AAC 62), Oil and Hazardous Substances Pollution Control (18 AAC 75)

DLA-DS area office and/or approved HW disposal contractors

Environmental Compliance Consultants (ECC) Clean Harbors (Defense Logistics Agency Disposition Services [DLA-DS] hazardous waste disposal contractor)

HW accumulation sites Various locations throughout Eielson AFB and adjacent training support sites, see table in Appendix B

HW accumulation time limits Hazardous Wastes – no more than 90 days from date of initial waste placement in container Universal Wastes – no more than 1 year (365 days) from date of initial waste placement in container

HW generator reporting frequency

Biennial

3 ENVIRONMENTAL MANAGEMENT SYSTEM

The AF adheres to the EMS framework and its Plan, Do, Check, Act cycle for ensuring mission success. Executive Order (EO) 13834, Efficient Federal Operations, U.S. Department of Defense Instruction (DoDI) 4715.17, Environmental Management Systems, AFI 32- 7001, Environmental Management, and International Organization for Standardization (ISO) 14001, Environmental management systems - Requirements with guidance for use, 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 manage associated risks, and instill a culture of continuous improvement. The HWMP serves as an administrative operational control that defines compliance-related activities and processes.

Environmental Action Plans (EAPs) are developed and maintained as part of the overall EMS on eDASH. EAPs are tools that translate environmental requirements and targets into actionable plans for the HWPM and responsible personnel. HW requirements should be incorporated in installation EAPs to record monitoring and conformance for inspections and audits.

4 ROLES AND RESPONSIBILITIES

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

Wing/Installation Commander

ESOHC

EMS CFT

HW Program Manager/Alternate(s) 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 (DLA) Disposition Services Tenant Organizations

AFCEC

Detailed information about typical responsibilities for these and other roles is available in AFMAN 32-7002, applicable installation supplements, and the HW Playbook. This plan implements these responsibilities for this installation. Additional HW management-related roles and responsibilities are described throughout this plan and in referenced documents.

Installation Supplement

354th Fighter Wing Commander (354 FW/CC)

The 354 FW/CC is ultimately responsible for ensuring compliance with laws governing HW management and proper disposal from all activities on base. The 354 FW/CC shall ensure:

The HWMP is current, available, and followed by installation personnel Proper disposal of all wastes from the installation That employees handling HW have HW responsibilities reflected in their job descriptions Use of the standardized Air Force HW system, Enterprise Environmental Safety Occupational Health-Management Information System (EESOH-MIS), to track waste generation and processes at CAAs and SAPs, cost, turn-in and disposal Resources are made available to successfully implement the HWMP Delegate the authority to sign HW manifests (in writing) to active duty or civilian employees

Environment, Safety, and Occupational Health Council (ESOHC)

The ESOHC will annually review and approve HW policies and guidance, review installation HWMPs and programs, monitor progress and advise leadership on HW issues.

Environmental Element (354 CES/CEIE)

354 CES/CEIE is the Office of Primary responsibility for seeing that all base functions comply with federal, state, local, and AF environmental regulations. 354 CES/CEIE provides all base groups with guidance and assistance in environmental matters, including writing and updating the HWMP. 354 CES/CEIE also ensures that HW training is made available and maintains training records.

354 CES/CEIE works closely with the Hazardous Waste Facility (HWF) to ensure proper HW handling and disposal. Primary concerns are the 90-day time limit and the completion of proper documentation, storage, and container labeling for HW transportation and disposal. Although the HWF is responsible for DD Form 1348-1, manifests, exception reports, and tracking open manifests, the 354 CES/CEIE ensures periodic waste characterization and reviews the waste profile sheets for all reoccurring waste streams.

354 CES/CEIE requests analytical services and forecasts future waste disposal requirements. 354 CES/CEIE conducts inspections of CAAs, SAPs, and UWPs. 354 CES/CEIE maintains a file on each CAA, SAP, and UWP, including inspection reports, shop operating instructions (SOIs), and any other site-specific information.

354 CES/CEIE works in coordination with Shop Supervisors/Managers to help identify and designate a shop as a CAA, SAP, or UW.

This determination is made by assessing how to best manage waste accumulation within shops to maintain compliance with AFMAN 32-7002 and relevant RCRA regulations.

HW Program Manager/Alternate

The 354 CES/CEIE Hazardous Water Program Manager serves as the primary technical point of contact for waste management policies and guidance for generators, accumulation point managers and disposal activities. They are responsible for compliance oversight to include planning, inspections, and execution of related requirements.

Restoration

Eielson AFB has been classified by the EPA as a "large quantity generator" of HW. As such, the installation commander or a designee is responsible for signing the manifests used to track the disposal of HW. Designation of individuals authorized to sign HW manifests will be made in writing and signed by the installation commander. This authorization shall be renewed or revised as needed by 354

CES/CEIE.

The 354 CES/CEIE Restoration Program staff act as key points of contact for the HW and other regulated waste disposal activity approvals, most notably with contaminated soil. They may receive, review, and approve DD Form 1348 disposition requests and sign manifests for off base waste shipments with appropriate training.

Air Force Civil Engineering Center

AFCEC provides technical and training support to personnel involved in HM management activities. The Air Force Civil Engineer Center is responsible for management of HW disposal funds. AFCEC staffs the Restoration Program at Eielson AFB.

Bioenvironmental Engineering

BE provides industrial hygiene and occupational health consulting services to all base personnel. This includes monitoring health and safety hazards for HW workers. BE also provides technical expertise on HW identification.

Radiation Safety Officer

The RSO coordinates the disposal of radioactive wastes with the United States Air Force School of Aerospace Medicine and the AF Radioactive Recycling and Disposal. Mixed waste disposal and handling will be coordinated with the Hazardous Waste Program Manager to comply with both RCRA and International Atomic Energy Agency regulations.

Safety

Wing Safety is the office of primary responsibility for Occupational, Safety and Health Administration (OSHA) requirements. They provide safety consulting services to all base personnel and monitor health and safety hazards for HM and HW workers and conduct safety inspections.

Unit Commanders

Unit commanders have onsite responsibility for environmental compliance and implementation of waste management activities at their facilities and activities. They appoint the Unit Environmental Coordinators and Accumulation Point Managers, as well as establish local management oversight as needed to provide full compliance with the HWMP and related regulatory requirements. Unit Commanders also ensure designated personnel complete and maintain required training and that all recordkeeping and reporting obligations are fulfilled.

Unit Environmental Coordinators

The UECs serve by appointment as the primary point of contact for Environmental Management System as described in AFI 32-7001.

In addition to managing and monitoring the EMS requirements for the unit, they provide information for environmental and sustainability performance indicators, support environmental compliance inspections, and assist with developing corrective actions to address identified findings.

Central Accumulation Area, Satellite Accumulation Point, and Universal Waste Point Supervisors/Managers

The Supervisors and Managers of CAAs, SAPs, and UWs provide shop-level oversight to ensure compliance with the HWMP. Within their respective organizations, they oversee implementation of corrective and preventive actions for identified environmental discrepancies. The primary and alternate site managers at the CAAs and SAPs are responsible for ensuring proper material (waste stream) segregation, storage, labeling, marking, initial spill response and base notification, and timely processing of containers to the HWF as described in this plan. Shop POCs must also coordinate with their Hazardous Materials counterparts at their shop to turn in excess/expired hazardous materials within three days of notification from HAZMART.

For any organization to initiate a CAA or SAP or to relocate an existing one, permission from 354 CES/CEIE is required. Any new or relocated CAA or SAP will also be coordinated with the fire department, BE, and safety prior to receiving CEIE approval. Once approved, an updated operating instruction (outlining new or different procedures) must be submitted to 354 CES/CEIE within 30 days. Following submission, an annual review of the SOI is required to address process changes, waste stream changes, and any other pertinent information.

Shop/HW Generator Personnel

For the purpose of this plan, a generator is any person or shop whose actions or processes produce a HW or whose actions first cause a HW to become subject to regulation. All individuals and shops on base that have HMs may coordinate with the HW Program Manager and HWF to determine if they should be designated as a CAA or a SAP. A shop that produces used oil will be managed as a SAP to ensure compliance with 40 CFR 279. A generator that either produces a UW disposed of through the HWF is a UW generator and must comply with this plan as mentioned in Section 1.0. Generators of HW must notify 354 CES/CEIE immediately and arrange for proper handling/disposal procedures. Maintenance being performed by personnel not part of the shop they are performing maintenance in must turn in HW to that shop's Manager, Alternate, or place waste in the appropriate CAA or SAP prior to leaving that shop.

Contracting Officer

Contracting Officers will provide contracting support and expertise for all contracts that either generate or require the disposal of waste, as well as for all waste-related contracts. Contracting Officers shall include all required and necessary contract provisions and clauses in service and construction contracts to ensure that Contractors engaged in work on Eielson AFB will generate, manage, and dispose of hazardous and other regulated wastes in a manner consistent with the requirements of this HWMP, and federal, state and DOD regulations. The Contracting Office also provides timely and effective contracting support to environmental managers to accomplish requirements of the HW management program, as appropriate.

Defense Logistics Agency - Disposition Services

DLA-DS is the disposal agent of record for all regulated waste disposal activities in the Department of Defense. They assume responsibility for the treatment, disposal, and/or recycling of the waste and assume liability on behalf of the DOD. To effect waste disposal, DLA-DS provides contracted waste services by a qualified contractor that uses DLA-audited transporters and disposal facilities. DLA-DS provides all HW disposal services for Eielson AFB in coordination with 354 CES/CEIE.

Tenant Organizations

All tenant organizations, including the 168th Air Refueling Wing (Alaska Air National Guard), Detachment 460 (Air Force Technical Applications Center), Arctic Survival School, Detachment 1 (66th Training Squadron), Detachment. 632 (Air Force Office of Special Investigations), Detachment 1 (210th Rescue Squadron), Detachment 25 (372nd Training Squadron), Civil Air Patrol (CAP), Army and Air Force Exchange Service (AAFES) and Defense Commissary Agency (DeCA) are subject to the requirements of this management plan and shall implement the requirements contained within to the extent that it applies to their respective hazardous and regulated waste generating activities. All tenant activities will coordinate their waste accumulation and management with the installation HW Manager.

Hazardous Waste Facility

The HWF holds the primary responsibility for HW stream inventory and with assistance from the HW Program Manager develops and implements a waste analysis program that complies with all Federal, State, and Local regulations (see the Waste Analysis Plan, Appendix A). The HWF assists 354 CES/CEIE to ensure proper waste handling and disposal. The HWF assists with requirements for documentation, including updating EESOH-MIS, storage, and container labeling for HW transportation and disposal. The HWF will be responsible for ensuring that calls from the accumulation points for waste pickups are documented and hazardous waste exceeding 55 gallons of hazardous waste or 1-quart of acute hazardous waste is picked up from SAPs within three consecutive calendar days of the call (not three working or business days). Additional responsibilities include completing DD Form 1348-1, manifests, exception reports, and tracking open manifests.

5 TRAINING

5.1. Hazardous waste training is required by law. All training requirements and sources are provided in the Environmental Training Matrix on eDASH. Specific local training procedures are provided in section 5.5.

5.2. Hazardous waste training is provided only by qualified authorized personnel. Training records are maintained IAW the Recordkeeping and Reporting section of this plan.

5.3. Hazardous waste program managers and alternates appointed in writing by the Wing Commander to sign manifests, require specific training to include HW Management Compliance Training and Department of Transportation training to sign HW manifests.

Installation HW Program Managers should complete the following in-residence courses (or equivalent): Air Force Institute of Technology (AFIT) 521, Hazardous Waste Management; and DLA - DCPSO00510, Transportation of Hazardous Material/Hazardous Waste (Interservice Environmental Education Review Board [ISEERB] approved). After initial course completion, refresher training is required annually for RCRA, and every 3-years for the DoT course. See training matrix for more information.

5.4. Function-Specific Training (Local In-House/On-Line Training Sources): (Group A) Organizational (non-central) Hazardous Waste Storage Area Managers, Satellite Accumulation Area (Initial Accumulation Point) Managers, and their immediate supervisor; and (Group B) all shop personnel, and their immediate supervisors, who generate HW.

All military and civilian personnel whose work involves hazardous or other regulated wastes, and their immediate supervisor, must successfully complete training appropriate to their job duties; See Table 1: Training Matrix for Key Personnel. Any individual who has not yet received HW training shall not perform any duties related to HW unless doing so under the direct supervision of a trained individual. All training records will be maintained in accordance with the Recordkeeping and Reporting section of this environmental management plan.

All contractor personnel whose work involves hazardous or other regulated wastes, and their immediate supervisor, must successfully complete training appropriate to their job duties. Any individual who has not yet received HW training shall not perform any duties related to HW unless doing so under the direct supervision of a trained individual. The prime contractor is responsible for ensuring all contract personnel are trained in accordance with federal Hazardous Waste Regulations (40 CFR § 262.17(a)(7) and 40 CFR § 273.36) and Hazardous Material Regulations (49 CFR § 172.704), as applicable. All training records will be maintained in accordance with the Recordkeeping and Reporting section of this HWMP.

All military and civilian personnel whose work involves hazardous or other regulated wastes, and their immediate supervisor, must successfully complete training appropriate to their job duties; See Table 1: Training Matrix for Key Personnel. Any individual who has not yet received HW training shall not perform any duties related to HW unless doing so under the direct supervision of a trained individual. All training records will be maintained in accordance with the Recordkeeping and Reporting section of this environmental management plan.

All contractor personnel whose work involves hazardous or other regulated wastes, and their immediate supervisor, must successfully complete training appropriate to their job duties. Any individual who has not yet received HW training shall not perform any duties related to HW unless doing so under the direct supervision of a trained individual. The prime contractor is responsible for ensuring all contract personnel are trained in accordance with federal Hazardous Waste Regulations (40 CFR § 262.17(a)(7) and 40 CFR § 273.36) and Hazardous Material Regulations (49 CFR § 172.704), as applicable. All training records will be maintained in accordance with the Recordkeeping and Reporting section of this HWMP.

TABLE 1: Training Matrix for Key Personnel

Type of Training

Key Personnel

Frequency

Available Course(s)

Regulator Citation(s

HW

Program Manager

UW

Program Manager

Personnel Authorized to Sign Uniform

Hazardous Waste

Manifests

CAA

Primary and Alternate

HW

Managers

Pharmacy with HW

Duties

All Other with HW

Duties

Facility Managers

Non- Delegated

UW

Point- of- Contact

RCRA HW

X

Annual

McCoy RCRA 5 Day Seminar McCoy RCRA 2-Day Seminar Air Force RCRA Annual Refresher / EAFB provided refresher seminar CBT

40 CFR § 262.17(a)(7)

DoT HM Employee

Every 3 years

Transportation of HM/HW for DoD

(DCPSO00R510)

49 CFR § 172.704

Defense Transportation Regulation (DTR) 4500.9-R, Part II, Chapter 204

OSHA HAZWOPER

40-Hour HAZWOPER Course (Initial) 8-Hour HAZWOPER (Refresher)

29 CFR § 1910.120

Air Force- Specific

One- Time

EAFB provided HW Management OR

(WENV 521)

AFMAN 32-7002,

Chapter 5, Section 6.1.5

Site-Specific X X X X X * Annual EAFB HW Manager Course

40 CFR § 262.17(a)(7)

**RCRA Non- Creditable HW Pharmaceuticals

Only if working at a pharmacy

EAFB HW

Manager Course

40 CFR § 266.502(b)

RCRA UW Only

X Annual Facility Manager

40 CFR § 273.36

RCRA UW

Only

Training provided and documented by UW Program Manager

40 CFR § 273.36

On-the-Job

Training provided and documented by a Primary / Alternate HW Manager

40 CFR § 266.502(b) 40 CFR § 262.17(a)(7)

NOTES: X = Required Training / * = Required Training (select one only) / **EAFB provided CBT for the Pharmacy

6 RECORDKEEPING AND REPORTING

Recordkeeping

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

NOTE: Retention time is defined by regulation as onsite and readily accessible for inspections and/or reference; after retention, the record(s) follow applicable Air Force Records Management rules.

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 (electronic or paper)

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 HW received from very small quantity generators.

40 CFR 262.17(f) 3 years from the date the HW 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)

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 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. Note that the records required by law or external regulation, should be readily available on-site. Records required by AF Record Retention requirements can be archived.

Reporting

The HW Program Manager, and other designated personnel, generate needed reports from the Enterprise Environmental, Safety, and Occupational Health - Management Information System (EESOH-MIS).

Enforcement actions, spills, and inspections are reported via the Enforcement Actions, Spills, and Inspections Environmental Reporting (EASIER) database.

CAA/SAP HW Binder

The CAA/SAP HW Binder is maintained at all facilities on Eielson AFB that have hazardous and/or universal waste accumulation points.

Usually, the HW Binder is under the control of the CAA or SAP site Manager, alternate, or supervisor. The CAA/SAP HW Binder shall include the information contained in this section. It is recommended the HW Binder has all the most recent procedure letters but must at the very least have the most recent procedure letters for the wastes produced in their shop. If any contents are not maintained in the CAA/SAP HW Binder, a cross-reference sheet must be included which shows the location of these documents.

Contents shall include but are not limited to:

Tab A Appointment Letters

A-1 Squadron Commander's Crew Chief Appointment Letter (Dating Back three years of appointees)

A-2 Squadron Unit Environmental Coordinator Appointment Letter

Tab B Guidance Documents

B-1 Shop Operating Instruction (SOI) B-2 Eielson AFB Hazardous Waste Management Plan B-3 AFMAN 32-7002, Chapter 5, Hazardous Waste Management

Tab C Training

C-1 Hazardous Waste Crew Chief Course Certificates and three full calendar years of certificates from previous Crew Chiefs.

C-2 Shop Hazardous Waste Training Program or Equivalent Training (for all shop personnel who handle waste)

Tab D Weekly Inspections

D-1 Current Year Inspections

D-2 Blank Inspection Forms

D-3 Three Full Calendar Years of Inspections

Tab E Hazardous Waste Tracking Forms

E-1 Container Log (Kept with Container) E-2 Blank Container Logs E-3 Container Logs (Three Full Calendar Years) E-4 HW Accumulation and Turn-In Log (Three Full Calendar Years)

E-5 Hazardous Waste Pickup Checklist (Three Full Calendar Years) (Required only at HWF)

Tab F Miscellaneous

F-1 Aerosol Can Disposal Management Procedure

F-2 Lamp Disposal Management Procedure

F-3 Battery Disposal Management Procedure

F-4 Oil and Fuel Filter Disposal Management Procedure (if applicable)

F-5 Contaminated Wipes Disposal Management Procedure (if applicable)

F-6 Waste Leather Gloves Waste Management Procedure

Tab G Sampling Results (if applicable)

G-1 Shop Laboratory Sample Results (Rags or Gloves if applicable)

Any shop that has been operating for less than three years is clearly unable to provide three full calendar years' worth of the needed information above but must provide all documentation up until the shop start date and then retain the necessary documentation stated above once they have been operating for three full calendar years.

Important to note, electronic copies of documentation are acceptable only if the organization keeps the storage media in the HW notebook and ensures a working computer is available to view the documentation upon a request of the Hazardous Waste Program Manager or regulatory agency personnel.

Hazardous Waste Facility

The HWF must maintain EESOH-MIS with detailed information on each container of waste disposed and will maintain the manifest notification reports for 50 years. The database must include:

Proper shipping name DOT ID number, hazard classifications Waste profile number Any other relevant information

Reports outlining all HW activities and disposal are available on-line through EESOH-MIS via the Ad-Hoc reporting tool.

354 CES/CEIE

354 CES/CEIE ensures that HW training is provided and maintains records of all training in EESOH-MIS, along with hard copies, and the review of profile sheets for all reoccurring waste streams. 354 CES/CEIE also maintains a file on each CAA and SAPs including inspection reports, SOIs, and any other site-specific information and reviews this information yearly to identify any improvements that may be made.

CAA and SAPs

The primary and alternate site managers are ultimately responsible for the day-to-day operation of each CAA or SAP and to ensure that the shop is maintaining compliance. Duties include:

Keeping accurate inspection records, training/documentation for shop personnel in proper waste handling and updating and reviewing the organization's SOIs annually.

Maintaining a container log (Appendix G – Container Logs).

Being responsible for all waste/used materials generated in their shop, including updating EESOH-MIS with relevant information.

Maintaining the HW shop binder and accurate inspection records for HW collection.

Immediately notify 354 CES/CEIE and HWF of any new changes to processes such as changes in process chemicals or constituents or changes of equipment or procedures within a process in order for wastes to be reevaluated/characterized.

7 PROCEDURES

This section contains procedures for managing HW from identification, accumulation, offsite transportation, and disposal. The HW Program 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, and select “Hazardous Waste” to generate the Waste Site Waste Stream Summary Report.

The resulting waste inventory report can be placed into Appendix B, Hazardous Waste Streams/Profiles.

Installation Supplement

HWF

The HWF is the office of primary responsibility for the HW stream inventory and waste analysis program development and implementation (see Appendix A – Waste Analysis Plan). The HWF maintains a database of HW streams in EESOH-MIS meeting the requirements dictated by Air Force policy AFMAN 32-7002.

AP and SAP

Each Accumulation Point Manager maintains an up-to-date listing of the types and quantities of each waste generated in the SAP.

Copies of the inventories are available from the accumulation point manager. If there is a need for a new recurring waste stream to be designated, or a waste stream to be re-evaluated, contact the base HW Manager

7.2 Waste Identification

The HW Program 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 Program 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

The Eielson AFB WAP (Appendix A) includes specific requirements for the identification and evaluation of hazardous wastes at the base. This plan contains base procedures for identifying and evaluating hazardous waste streams in order to complete a hazardous waste profile sheet (HWPS)/(DLA-DS Form 2511) on each hazardous waste stream.

Appendix A is maintained as a separate document and is only required by HWF personnel responsible for collecting and requesting samples in order to make HW determinations and manage used oil.

7.3 Container Management

Container management procedures are as follows:

Containers storing HW must be in good condition and meet 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. The required headspace is unique to each waste stream and expected storage conditions. For liquids and volatile chemicals, a general rule is to not fill to more than 85% of container capacity to allow for temperature changes, and this equates to approximately four inches of headspace in a typical 55-gallon drum. The ultimate requirement is performance based, such that drums do not bulge or leak. A good inspection process will enable any recommendations for specific waste streams as appropriate.

Containers holding HW must not be opened, handled, or stored in a manner which may rupture the container or cause it to leak.

Containers of flammable liquids must be grounded when transferring flammable liquids from one container to the other.

Container management procedures are specified in the HWF and SAP SOIs (an example template is attached in Appendix B).

Containers must meet DOT specifications for structural and chemical compatibility as well as containment requirements in 40 CFR§262. Containers can be requested from the HWF. Do not use a previously filled and now empty product container, with the exception of using empty oil container to collect used oil as long as that container remains undamaged. Every container must be properly labeled and marked IAW the requirements outlined in the Labeling and Marking Section.

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

• Do not overfill liquid containers (maximum 80% fill, to allow for content expansion). Example: Only fill 55-gallon drums with 45 gallons of waste. Liquids expand in containers when temperatures rise. The pressure created by the expansion of the liquid can compromise the integrity of the container. Keep in mind the temperature fluctuations this installation experiences.

• Protect containers from freezing in cold temperatures. Freezing causes metal stress and can result in damage to containers.

• Containers holding ignitable liquid must be grounded when transferring liquids. Grounding will prevent build-up of static electricity that may create a spark capable of igniting flammable vapors. Safety Office and/or Fire Department can provide details on grounding containers.

• Utilize an approved funnel, placed in the bung, to fill closed head containers. This will ensure that all waste is poured into the container and does not spill on the top of it. After filling, the funnel should be removed and the bung closed. Funnels that are to remain in place must possess a closure device designed to keep the container contents from spilling in case of accidental tip-over, per 40 CFR§262.15 and 262.17.

• For non-flammable liquids, do not stack containers more than two containers high. Containers containing flammable liquids shall not be stacked.

• If containers must be stored outdoors, they shall be stored in an area protected from precipitation.

All waste must be handled in such a way as to prevent spills from occurring. Waste must be kept out of traffic areas and placed against a wall. Waste must only be placed in DOT-approved containers for the waste type. Containers shall not have excessive rust and chimes/seams must be free of dents, creases, and sharp edges. Containers must not be bulging. Adequate aisle space (minimum of 3ft) shall be maintained to allow for the movement of spill response equipment and personnel in case of a spill or fire. The contents of a damaged or leaking container must be immediately transferred to an undamaged container in a manner that prevents spills or placed in a overpack or salvage Container.

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 an IAP 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 ID Number Manifest tracking

These markings are:

Durable In English 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

Universal waste (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 one 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)”

CAA and SAP

All containers collecting HMs and HWs must be properly labeled with either legible handwriting or a printed label. Contact the HWF prior to placing waste in the proper container and they will assign a container number. The assigned number must be placed on the container. Labeling must be IAW 49 CFR Part 172.304. Label placement and marking is as follows:

All labeling must be visible and readable from one position.

Labels may be placed on a securely affixed tag if the container surface is irregular or the labels cannot be satisfactorily affixed.

When two or more labels are required, they must be displayed affixed next to each other.

If unable to create a label at the time waste is placed in the container, the following marking is allowed until a…