_J-0200000-11.a_Hazardous_Waste_Management_Plan.pdf

HAZARDOUS WASTE

MANAGEMENT PLAN

Naval Station Rota, Spain

May 2016 (Reviewed by NAVSTA HWPM)

APPROVALS

This Hazardous Waste Management Plan addresses management requirements specific to current regulated waste generation and disposal activities at Naval Station Rota, Spain.

Approved By:

CAPT, M. D. MACNICHOLL USN Date

Commanding Officer

NAVSTA Rota, Spain

Date

Amos Webb

Installation Environmental Program Director NAVSTA Rota, Spain

Maria del Carmen Dominguez Date

Hazardous Waste Program Manager

NAVSTA Rota, Spain

Hazardous Waste Management Plan

Maricarmen.Domin.SP Inserted Text November 15, 2018

HAZARDOUS WASTE MANAGEMENT PLAN

RECORD OF REVISIONS

The following table is provided for tracking revisions to this plan. This document shall be updated, revised, and reissued at least every five years. Additionally, the plan shall be reviewed at least annually by the Naval Station Rota Hazardous Waste Program Manager

(HWPM). This plan shall be updated as necessary to reflect changes in hazardous waste management. If a change in management practices, regulatory requirements, or site conditions result in the need for a revision between scheduled annual reviews, the revision to the management plan will be made within 90 days of the change occurring.

Relevant information regarding changes shall be communicated to all affected users of the

HWMP. Instructions to these entities regarding implementation of the changes shall be provided by the HWPM.

Each review and/or revision shall be documented in the table below. If no revisions are made as a result of the review, the review will be documented and “none” shall be entered into the “description of changes” column.

Date Review Name/Title Signature Description of Change(s)

Hazardous

Naval

Station Rota, Spain 2

TABLE OF CONTENTS

TABLE OF CONTENTS 2

LIST OF TABLES 2

TABLE 1-1: HAZARDOUS WASTE REGULATORY CROSS-REFERENCE

TABLE 5-1: RECORDS RETENTION MATRIX

TABLE 6-1: TRAINING REQUIREMENTS

LIST OF APPENDICES 2

APPENDIX A – STANDARD OPERATING PROCEDURES

APPENDIX B – HWAP LOCATIONS

APPENDIX C – WASTE ANALYSIS PLAN

ACRONYMS AND ABBREVIATIONS 3

GLOSSARY 6

1 INTRODUCTION 7

2 RESPONSIBILITIES 9

2.1 SPANISH BASE COMMANDER (SBC) 9

2.2 NAVSTA ROTA COMMANDING OFFICER 9

2.3 INSTALLATION ENVIRONMENTAL PROGRAMS DIRECTOR (IEPD) 9

2.4 NAVSTA Rota Hazardous Waste Program Manager 9

2.5 Defense Logistics Agency Disposition Services 9

2.6 ACTIVITY ENVIRONMENTAL COORDINATORS 10

2.7 NAVFAC FACILITIES ENGINEERING AND ACQUISITION DIVISION 10

3 HAZARDOUS WASTE ACCUMULATION AND STORAGE 10

3.1 Hazardous Waste Accumulation Points 11

3.2 Hazardous Waste Storage Area 11

4 HAZARDOUS WASTE MANAGEMENT PROCEDURES 11

4.1 Hazardous Waste Identification 11

4.2 General Container Management and Handling 12

4.2.1 WASTE SEGREGATION 12

4.2.2 CONTAINER TYPES 12

4.2.3 LABELING 12

4.2.4 SPILL PREVENTION 12

4.2.5 SECONDARY CONTAINMENT 12

4.2.6 OVERFILLING 13

4.2.7 IGNITABLE OR REACTIVE WASTES 13

4.2.8 TRANSPORTATION 13

4.3 Hazardous Waste Accumulation Points 13

4.3.1 HAZARDOUS WASTE ACCUMULATION POINT INSPECTIONS 13

4.3.2 CONTINUITY BINDER 13

4.3.3 TURN-IN OF HAZARDOUS WASTE 14

4.4 Hazardous Waste Storage Area Procedures 14

4.4.1 EQUIPMENT 14

4.4.2 SEGREGATION 15

4.4.3 INSPECTIONS 15

Naval Station Rota, Spain 3

4.4.4 SECURITY 15

4.4.5 DISPOSAL PROCEDURES 16

4.5 Turn-in of Excess Hazardous Materials from Transient Ships 16

4.6 Turn-in of Excess Hazardous Materials from Homeported Ships 16

5 REPORTING AND RECORDKEEPING 16

5.1 Spanish Waste Manifest 16

5.2 Annual Reports 18

5.3 Records Retention 18

6 TRAINING 19

7 CONTINGENCY PLAN 20

7.1 Spill Prevention and Response Plan 20

7.2 Pollution Prevention and Waste Minimization 20

8 CLOSURE PLAN 22

8.1 Estimated Hazardous Waste Storage Capacity 22

8.2 Hazardous Waste Removal/General Decontamination 22

8.2.1 DECONTAMINATION OF NON-POROUS SURFACES 23

8.2.2 DECONTAMINATION OF POROUS SURFACES 23

8.2.3 REMOVAL OF GROUND MEDIA 23

8.3 Possible Contaminants of Concern 23

8.4 Expected Closure Date 24

9 REFERENCES 25

Naval Station Rota, Spain 4

ACRONYMS AND ABBREVIATIONS

ADR European Agreement Concerning the International Carriage of Dangerous

Goods by Road

ASTM American Society for Testing and Materials

AUL Authorized User List

CFR United States Code of Federal Regulations

CHRIMP Consolidated Hazardous Material Reutilization and Inventory Management

Program

CLIN Contract Line Item Numbers

CNREURAFSWA Commander Navy Region, Europe Africa and Southwest Asia

COLIWASA Composite Liquid Waste Sampler

COR Contracting Officer Representative

CTF-63 Commander Task Force Naples, IT

DD-1348-1A Defense Department property transfer form

DLA DS Defense Logistics Agency Disposition Services

DO Delivery Order

DoD Department of Defense

DoDI Department of Defense Instruction

DODAAC Department of Defense Activity Address Code

DoN Department of Navy

DOT United States Department of Transportation

DTID Disposal Turn-In Document

EC Environmental Coordinator

EMS Environmental Management System

EPA United States Environmental Protection Agency

EU European Union

EWC European Waste Catalogue

FGS Final Governing Standards

FIC Facility Incident Commander

FP Flash Point

HAZCOM Hazard Communication

HM Hazardous Materials

HAZWOPER Hazardous Waste Operation and Emergency Response

HMIS Hazardous Material Information System

HSIRM Hazardous Substance Incident Response Management

HWAP Hazardous Waste Accumulation Point

HW Hazardous Waste

HWMP Hazardous Waste Management Plan

HWPM Hazardous Waste Program Manager

HWPS Hazardous Waste Profile Sheet

HWSA Hazardous Waste Storage Area

L Liter mL Milliliter

NAVFAC Naval Facilities Engineering Command

NAVSTA Naval Station

NAVSUP Naval Supply Systems Command

NFPA United States National Fire Protection Association

NOSC Navy On-Scene Coordinator

NSN National Stock Number

OPNAV Office of the Chief of Naval Operations

OPNAVINST Office of the Chief of Naval Operations Instruction

P2 Pollution Prevention

P2ADS Pollution Prevention Annual Data Summary

Naval Station Rota, Spain 5

PCB Polychlorinated Biphenyls

POC Point of Contact

POL Petroleum, Oil, and Lubricants

PPE Personal Protective Equipment

PWD Public Works Department

QA Quality Assurance

QC Quality Control

RCRA Resource Conservation and Recovery Act

SDS Safety Data Sheet

SOP Standard Operating Procedures

SPRP Spill Prevention and Response Plan

TCLP Toxicity Characteristic Leaching Procedure

US United States

UIC Unit Identification Code

WAP Waste Analysis Plan

Naval Station Rota, Spain 6

GLOSSARY

In addition to the definitions provided in Chapter 6 (Hazardous Waste) of the

Environmental Final Governing Standards for Spain, the following terms are included in this Hazardous

Waste Management Plan.

Excess hazardous material – Hazardous materials used on a ship that are to be offloaded for determination as reusable hazardous material or disposal as hazardous waste.

Generating activity – organization that is creating the hazardous waste.

Numero de identificación fiscal (NIF) – An identifier used in many countries, including the countries of the European Union for Value Added Tax purposes.

Naval Station Rota, Spain 7

1 INTRODUCTION

Activities at Naval Station (NAVSTA) Rota, Spain generate hazardous waste (HW) and excess hazardous materials (HM) during routine operations, such as maintenance and repair activities. The proper management and disposal of the HW is necessary to protect the health and safety of personnel aboard NAVSTA Rota and the local environment.

This Hazardous Waste Management Plan (HWMP) has been developed to provide guidance related to the management of hazardous waste (HW) handling, storage, and disposal activities at NAVSTA Rota, Spain. The Hazardous Waste Program Manager (HWPM) is responsible for development, maintenance, and oversight of the implementation of this HWMP. The HWMP is specifically designed to be a working tool and to address the responsibilities and actions required of affected personnel in order to comply with requirements for the management of HW at NAVSTA Rota. These requirements are established by the Environmental Final Governing Standards for Spain (FGS-Spain), and by policies, instructions, and other applicable directives issued by Department of Defense (DoD); Department of Navy (DoN);

Commander Navy Region Europe, Africa, and Southwest Asia (CNREURAFSWA); and NAVSTA Rota.

Throughout this HWMP, all subsequent citations from the FGS-Spain are simply referred to as the

“FGS.” In addition, it should be noted that the nomenclature for FGS section numbers includes a reference to the FGS chapter and paragraph (for example, FGS Section C6.3.1 refers to FGS Chapter 6, Paragraph 3.1). Table 1-1 provides a cross-reference between the current (2014) FGS-Spain requirements and the location of the corresponding information in this plan.

The HWMP will be kept current to reflect changes in regulatory requirements and waste management activities conducted at NAVSTA Rota. The plan will be reviewed at least annually and revised as necessary (at least every five years) by the NAVSTA Rota HWPM in accordance with the instructions to the “Hazardous Waste Management Plan Record of Revisions” located at the front of this plan.

Naval Station Rota, Spain 8

Table 1-1: Hazardous Waste Regulatory Cross-reference

Applicable

FGS-Spain (May 2014)

Requirement Description HWMP Section(s)

C6.3.2. Hazardous Waste Accumulation Point (HWAP) 3.1

C6.3.3. Hazardous Waste Storage Area (HWSA) 3.2

C6.3.4. Use and Management of Containers 4.2

C6.3.5. Recordkeeping Requirements 5

C6.3.6 Contingency Plan 7

C6.3.7. Tank Systems N/A

C.6.3.9. Hazardous Waste Training 6

C6.3.10. Hazardous Waste Disposal 4.4.5.

Waste Management Plan

Naval Station Rota, Spain 9

2 RESPONSIBILITIES

Responsibilities for implementing this plan are distributed throughout NAVSTA Rota. Tasked organizations, contractors and individuals must work together to ensure effective management of the HW program. The primary program responsibilities for organizations and personnel tasked with HW management roles are described in the following paragraphs.

Other secondary responsibilities are included throughout this plan.

2.1 SPANISH BASE COMMANDER (SBC)

• Contacts the Environmental Executive Agent (EEA) via the Component

Chain of Command

• Serves as liaison between the EEA, NAVFAC PW Environmental Division, and the local authorities.

2.2 NAVSTA ROTA COMMANDING OFFICER

• Ensures that the responsibilities for the management of HW are carried out.

• Signs the HWMP to require implementation of its requirements throughout

NAVSTA Rota

2.3 INSTALLATION ENVIRONMENTAL PROGRAMS DIRECTOR

(IEDP)

• Oversees the administration and general maintenance of the Installation’s Hazardous

Waste Storage Area (HWSA)

2.4 NAVSTA ROTA HAZARDOUS WASTE PROGRAM MANAGER

• Assumes overall management of the HW program and reports status to the installation environmental program director (IEPD)

• Provides guidance to all NAVSTA Rota personnel to ensure proper management of HW through the implementation of the HWMP and other requirements

• Provides technical information and assistance to HW-generating activities at NAVSTA Rota

• Ensures that the HW management program requirements are integrated into the NAVSTA

Rota environmental management system (EMS) and monitored appropriately

• Review and approve the HWMP

• Assist generating activities in establishing HW accumulation points (HWAPs)

• Conduct the annual compliance assessment of the HW management program to meet EMS requirements

• Coordinates HW training and maintain records as required by FGS

• Completes and submits all reports on HW management to Navy and host nation agencies

(via the Spanish Base Commander) as required

• Maintain copies hazardous waste management operations such as Training Certificates, ETIDs, HWPSs, and administrative records as required by the FGS

• Coordinates with DLA COR any changes in the HW disposal process

2.5 DEFENSE LOGISTICS AGENCY DISPOSITION SERVICES

• Serves as the hazardous waste disposal agency for DoD. DLADS provides contract services for regulated waste disposal.

• DLA HW COR reviews/approves HW disposal ETIDs for NAVSTA EV Coordinators.

Naval Station Rota, Spain 10

• DLA Onsite HW Contractor weighs HW consignment and verifies turn in documents and send copies to DLA HW COR to generate Task Orders and process for HW documentation through DLA for removal

• Oversees HW Contractor and will ensures that all pertinent hazardous waste information is correctly tracked by the DLA HW Contractor, as well as all rejection notice.

2.6 ACTIVITY ENVIRONMENTAL COORDINATORS

Serve as the environmental POCs for departments, tenant commands, and contractors operating aboard NAVSTA Rota. EVCs are the first line of communication with the NAVSTA

Rota Environmental Department and assume basic environmental responsibilities within their units

NAVSTA Department/Tenant Commands generating hazardous waste must designate in writing personnel to serve as the EV Coordinator and an alternate to assume responsibilities for the proper accumulation, storage, and disposal of the

HW. Designated EVCs will assume overall responsibilities for management of HW of each HWAP within their Department, while generators of HW must be capable of recognizing, tracking, and maintaining all necessary documentation and processes for proper HW management.

Main duties of the EVCs include, but are not limited to, the following tasks:

Collecting, containerizing, labelling, and marking containers of HW in accordance with this plan

Ensuring all personnel who handle HW or who are otherwise involved in the HW management within their Department are identified and receive required training.

Managing Department HWAP(s) in accordance with FGS requirements.

Performing and documenting weekly inspections of the HWAP(s) with follow up on all corrective actions.

Allow facilities, shops, and equipment to be inspected (e.g., Safety inspectors, NAVFAC EV inspectors, Regional Environmental Agency)

Preparing all necessary disposal documents and transporting HW from the HWAP to the HWSA.

Ensuring maintenance and retention of HW documents, according to Spanish FGS (e.g., Weekly inspections, ETID-DD Form 1348-1A, HWPS, Training records, etc)

Creating and maintaining a Department HW Continuity Binder as described in section 4.3.2 of this

HWMP

2.7 NAVFAC FACILITIES ENGINEERING AND ACQUISITION

DIVISION

Ensures that contracts for all work to be accomplished at NAVSTA Rota include the condition that Contractors shall conform to all requirements of the FGS, Spanish and local requirements, OPNAV environmental instructions and this HWMP.

NAVFAC Engineering and Acquisition Director ensures EV Deficiencies from

Contractors will be send to NAVFAC EV Director as well as corrections within 30 days of notifications.

Naval Station Rota, Spain 11

3 HAZARDOUS WASTE ACCUMULATION AND

STORAGE

HWAPs and HWSA are managed in accordance with Spanish FGS, Chapter 6.

3.1 HAZARDOUS WASTE ACCUMULATION POINTS

A HWAP at NAVSTA Rota is a shop, site, or other work center where hazardous wastes are accumulated until removed to the Hazardous Waste Storage Are (HWSA) or shipped for treatment or disposal. A HWAP may be used to accumulate <210 liters (55 gallons) of hazardous waste, or 1 liter (1 quart) of acute hazardous waste, from each waste stream.

The HWAP must be at or near the point of generation and under the control of the

Department EV Coordinator. The HWAP must be designated and operated to provide appropriate segregation for the different waste streams, including those that are chemically incompatible. Each HWAP will have warning signs (National Fire Protection Association –

NFPA) or appropriate warning signs appropriate for the waste being accumulated. The HWAP will meet all standards of the Spanish FGS, Chapter 6.

When these limits have been reached or when an individual storage container is full, EVC must prepare necessary disposal ETID documents and transfer full container(s) to the HWSA within five days. All HW Generated at the HWAP must meet all FGS Chapter 6, standards.

Naval Station Rota does not transport HW off-site for disposal directly from the HWAPs.

3.2 HAZARDOUS WASTE STORAGE AREA

The HWSA at NAVSTA Rota is used to deposit and process all of the containers of HW generated at HWAPs base-wide, and is operated by the Defense Logistics Agency Disposition

Services (DLA-DS) HW contractor. The HWSA is a fenced area with a building that provides for segregated storage, a shelter to provide cover for the HW container processing area, shelving for storage of containers, and a modular unit that serves as an office for the DLA-

DS HW contractor. The HWSA is located at Building 1811 at NAVSTA Rota and has been specifically located in such a way as to meet the location and design requirements of FGS-

Spain. Per FGS requirements, hazardous wastes will not be stored in the HWSA for longer than six months. If necessary, installation will request an extension by providing sufficient information to the SBC for approval to store waste greater than six months.

The HWSA is open to accept and process HW from 07:30 – 16:30 Monday through Friday.

Generating activity EVCs are aware of these operating hours and make arrangements to deliver HW only during those hours.

4 HAZARDOUS WASTE MANAGEMENT PROCEDURES

4.1 HAZARDOUS WASTE IDENTIFICATION

Generally, if a waste presents potential harm to people or the environment, it will be treated as a HW. Hazardous waste can be identified by a hazardous characteristic

(flammability, corrosivity, reactivity, or toxicity) or by being specifically listed in FGS-

Spain, Addendum 2, European Waste Codes. With support and guidance from the HWPM, the EC at generating activities identify the materials and processes which create wastes and determine which of these wastes must be managed and disposed as HW. A HW profile sheet is completed by the EVC for each waste stream generated by the activity and

Naval Station Rota, Spain 12 submitted via DLA AMPS/ETID Website. DLA HW COR reviews and accepts before that waste is accumulated and transported to the HWSA. The profile will be kept in the

Department EV Continuity Binder by the EVC. Master copy of the HWPSs will be maintained by the DLA HW COR. If the process or materials involved in generating the waste change, a new HW profile is submitted to document the new waste stream by generated

Department EVC.

The waste analysis plan (WAP) is included as Appendix C.

4.2 GENERAL CONTAINER MANAGEMENT AND HANDLING

The ECs assigned in each area are responsible for the management of HW in that activity. Hazardous waste must be accumulated only in HWAPs.

4.2.1 WASTE SEGREGATION

Waste stream integrity is maintained in the HWAPs. Each generating activity must be able to account for exactly what wastes go into each container, and segregation of these wastes and of HW from other wastes must be maintained. This is typically accomplished by secured containers with controlled access. Waste segregation is also important from a safety perspective. Mixing of incompatible wastes may cause a fire, explosion, or release of toxic vapors. To protect against such occurrences, each waste stream is accumulated in separate containers compatible with the hazardous waste and the containers are physically separated to prevent commingling of the HW.

4.2.2 CONTAINER TYPES

As necessary, generating activities will purchase and use appropriate DOT/ADR-certified drums and UN cardboard boxes to accumulate HW. These containers are obtained from the

DLA Distribution Services HW contractor or from other sources and are paid for by the using activity. Department EVCs will be considering compatibility of materials with appropriate disposal container, rate of generation and cost for disposal. For example, if only 25 gallons of a material are generated in six months, it is more effective to select a 30 gallon container than a 55 gallon container. Similarly, if the activity is generating liquid waste, a closed-top container should be selected.

Hazardous waste is turned in to the HWSA in these containers and are not repackaged for disposal unless there are container deficiencies identified. Containers at the HWAPs and in the HWSA are kept in good condition, free from severe rusting, bulging, or structural defects.

All containers used for the accumulation of waste are compatible with the HW being deposited.

4.2.3 LABELING

Hazardous waste drums must have a bilingual label to identify:

• European waste code

• HW Generator Name, UIC, and contact information of generating activity

• Technical name of the HW

• Start and end dates of accumulation

• Hazard class of the HW contained

• ETID number

4.2.4 SPILL PREVENTION

Hazardous waste containers are closed during accumulation and storage, except when it is necessary to add or remove waste. Containers are stored in HWAPs in such a way as to prevent rupture and minimize the likelihood of being tipped over or otherwise damaged.

Containers holding flammable liquids must be grounded. The EVC at generating activities monitor the containers daily and each generating activity retains appropriate spill cleanup

Naval Station Rota, Spain 13 materials on-site for use in the event of a spill. Spent spill cleanup materials are containerized and disposed as HW.

4.2.5 SECONDARY CONTAINMENT

Hazardous waste containers of free liquids are placed in secondary containment that is impervious and able to contain leaks, spills, and precipitation. The containment will be sized to contain either 10% of the total volume of stored containers or the total volume of the largest single container, whichever is greater. Containment may include spill pallets, storage lockers with containment, imperviously bermed areas, or other such control structures.

Hazardous waste containers that do not contain free liquids are not required to be on secondary containment, but are required to be placed in HWAPs that allow for protection from exposure to the elements.

4.2.6 OVERFILLING

HW containers are not filled over 90% of their capacity to allow adequate head space for the potential expansion of liquids and HW vapors.

4.2.7 IGNITABLE OR REACTIVE WASTES

All HWAPs are located a minimum of 15 meters from the property boundary. In addition, HWs that are ignitable or otherwise reactive are protected from sources of ignition or reaction, including but not limited to: open flames, smoking, sparks, and spontaneous ignition. Water-reactive wastes and oxidizers are separated from flammable and combustible liquids, and containers of flammable liquids are grounded.

4.2.8 TRANSPORTATION

In accordance with the procedures in appendix A, containers of HW are transported using equipment designed for the task, and containers are secured to pallets before moving the pallet. The EVC for each generating activity is responsible for safely transporting the containers from the HWAP to the HWSA. When transporting HW only government owned vehicles (GOVs) will be used. No personnel at NAVSTA Rota are authorized to transport HW outside of the installation boundary or along public roadways.

4.3 HAZARDOUS WASTE ACCUMULATION POINTS

In addition to the requirements of sections 4.1 and 4.2, personnel will adhere to the following procedures for the management of HWAPs. A list of HWAPs is provided in Appendix A.

Each HWAP is specifically designated at or near the point of generation and provided with appropriate NPFA or International signage.

No more than 208 liters (55 gallons) per waste stream may be accumulated at the

HWAP.

4.3.1 HAZARDOUS WASTE ACCUMULATION POINT INSPECTIONS

HWAPs are inspected weekly by Department EVCs for leaks and deterioration of containers.

Secondary containment systems are inspected for defects and accumulating liquids.

Inspections are documented using form provided by NAVFAC Environmental Office.

4.3.2 CONTINUITY BINDER

Each generating activity EVC maintains an Environmental Continuity Binder to document HW management activities. At a minimum, the binder contains:

• Contact information for pertinent personnel associated with EV Program management

Naval Station Rota, Spain 14

• Training records for three years after termination of duty of personnel

• HW weekly inspections for three years

• HW profile sheets for three years

• Completed HW turn-in documents for five years

• Extra Department EV information need it

Maintaining Department EV continuity binder is the responsibility of the EVC, and is turned over with personnel changes. If the HWAP closes, the binder is submitted to the HWPM for archiving.

4.3.3 TURN-IN OF HAZARDOUS WASTE

A HW profile sheet is completed by the EVC for each waste stream generated by the activity and submitted via DLA AMPS/ETID Website for DLA HW COR to review and acceptance before that waste is accumulated/transported from the HWAP to the HWSA. The profile will be kept at the DLA AMPS/ETID Website, also in the continuity binder by the EVC.

Once the HW container at the HWAP is 90% full, the container is sealed and prepared for delivery to the HWSA within five working days after receiving approved ETID for timely disposal. The EVC works with the DLA Disposition Services HW Contracting Officer

Representative (COR) to enter the container into the DLA Disposition Services Electronic

Turn-In Document (ETID) system. The DLA Disposition Services HW COR trains each EVC on the process to access the system, register as a user and enter the required information.

Once the container information is entered into ETID, the DLA Disposition Services HW COR reviews it, recommends corrections or adjustments by the EVC if necessary, and forwards to EVC ETID generator who will sign it and send it to HWPM for signature. HWPM sends signed ETIDs to generated ETID EVC and HW Contractor for final disposal process.

Once the documentation has been approved, Department EVCs will print copies of the turn-in document and profile, and transport the HW container(s) to the HWSA during operating hours. There, the DLA

Disposition Services HW contractor reviews paperwork, inspects the container, logs it into the facility inventory, weight and places it in the proper storage area. If the turn-in does not meet the requirements for the container and/or the documentation, DLA HW Contractor provides the EVC with a rejection notice. The EVC must return the container to the HWAP and has 48 hours to correct the deficiency and return the container to the HWSA. DLA HW contractor and DLA Disposition Services HW COR track all rejection notices. If the HW is accepted, the EVC will receive a copy of the accepted turn-in document that is then placed in the continuity binder. The DLA Disposition Services HW COR adds the container to the delivery order directly from the ETID system.

4.4 HAZARDOUS WASTE STORAGE AREA PROCEDURES

In addition to the requirements of sections 4.1 and 4.2, personnel will adhere to the following procedures for the management of HWAPs. The HWSA at NAVSTA Rota is located at Building

1811.

The HWSA is designed, constructed, maintained, and operated to minimize the possibility of a fire, explosion, or any unplanned release of HW constituents to air, soil, groundwater, or surface water that could threaten human health or the environment. Any modification to the existing HWSA or construction of a new HWSA must also meet these requirements. HW should not be stored longer than 180 days (6 months) without an operating permit.

4.4.1 EQUIPMENT

The HWSA is equipped with the following:

• An internal communications or alarm system capable of providing immediate emergency instruction (voice or signal) to HWSA personnel.

Naval Station Rota, Spain 15

• A device such as an intrinsically safe telephone (immediately available at the scene of operations), or a hand-held two-way radio, for the summoning of emergency assistance from Installation security, fire departments, or emergency response teams.

• Portable fire extinguishers, fire control equipment appropriate to the material in storage, spill control equipment, and decontamination equipment.

• Water at adequate volume and pressure to supply water hose streams, foam producing equipment, automatic sprinklers, or water spray systems.

• Readily available PPE (appropriate to the materials stored), eyewash station, and shower facilities.

Testing and maintenance is performed by DLA HW Contractor for all HWSA equipment to ensure proper operation in time of emergency.

4.4.2 SEGREGATION

The HWSA provides appropriate segregation for HW through its design and operation. The

DLA Disposition Services HW contractor ensures that HW are compatible with their containers and are located in the properly designated locations. Ignitable, reactive, or incompatible wastes are stored to the north of the HWSA in an enclosed Building 1811 comprised of six separate walled compartments to prevent potential threat to human health or the environment. All HW liquid containers with flammables will be stored at Flammable Lockers located at HWSA Compound.

4.4.3 INSPECTIONS

Minimum frequencies of monitoring HWSA by the DLA HW contractor are as follows:

• Containment storage areas must be inspected weekly for leaks and deteriorating containers and containment systems. Secondary containment systems shall be emptied of accumulated releases or storm water and inspected for defects.

• Areas subject to spills (loading and unloading areas) are inspected daily when in use.

The DLA HW Contractor inspects HWSA monthly for malfunctions, deterioration and discharges that may occur, or result in, a release of HW constituents to the environment or threat to human health. DLA HW Contractor will inform the HWMP for any problems or deteriorations at the HWSA. Inspections by the HWPM are conducted annually.

Inspections include all equipment and areas involved in storage and handling of HW, including all containers and container storage areas, and all monitoring equipment, safety and emergency equipment, security devices, and operating and structural equipment (such as dikes and sump pumps) that are important to preventing, detecting, or responding to environmental threats or human health hazards. Inspection records are retained and include the date and time of inspection, name of inspector, notation of the observations made, and the date and nature of any repairs or other remedial actions. The appropriate form for conducting the inspections is provided by the HWPM in appendix A of this plan.

NAVSTA Rota is responsible for remedying any deterioration or malfunction of equipment or structures that the inspection identifies on a schedule which ensures that the problem does not lead to an environmental or human health hazard. The DLA Disposition Services HW contractor tracks all inspection deficiencies until deficiencies are corrected. Inspection forms must be available for HWPM & DLA HW COR.

4.4.4 SECURITY

The HWSA is secured to prevent any unknown entry, and to minimize the possibility for unauthorized entry onto the HWSA grounds. A fence in good repair completely surrounds the HWSA, combined with a locked gate to control entrance at all times. Additionally, NAVSTA Rota security performs periodic surveillance rounds in the vicinity of the HWSA

Naval Station Rota, Spain 16 perimeter. During operating hours, the DLA Disposition Service contractor is present onsite at the HWSA.

A sign is posted at the HWSA, in English and Spanish, with the words, “Danger Unauthorized

Personnel Keep Out, Peligro, No permitida la entrada a personal no autorizado”. This sign is legible from a distance of at least 25 feet as required.

4.4.5 DISPOSAL PROCEDURES

HW is disposed through DLA Disposition Services.

In preparation for disposal of the HW from the HWSA, the DLA Disposition Services HW COR prepares a delivery order request and submits it to the DLA Disposition Services HW disposal contractor. The HW disposal contractor prepares a Spanish waste manifest, and returns the manifest to NAVFAC PW EV office HWMP to obtain designated signatory from Military POCs.

The DLA Disposition Services HW contractor and the DLA Disposition Services HW COR, are present for the HW pick-up by the HW disposal contractor. Only the designated member(s) of the military is (are) authorized to sign the manifest prior to departure.

4.5 TURN-IN OF EXCESS HAZARDOUS MATERIALS FROM

TRANSIENT SHIPS

When coming into port at NAVSTA Rota, transient ships may request permission to offload excess hazardous materials. This request is made to COMSERVFORSIXTHFLT (CTF63) in

Naples. CTF 63 Naples will approve funds and approved documents for the offload. These documents will be provided to the requesting ship and to NAVSTA Rota NAVFAC PWD

Environmental Division HWPM.

Before offloading begins in-port, HWPM/NAVSUP Afloat Technician and designated ship personnel will ensure that the turn-in documents are completed and signed, SDSs for the material being offloaded is provided, and that the corresponding container is properly labeled

(Bilingual HW Labels will be provide by HWPM) with the Ship’s name, document number, and the type/name of material contained. Prior to offloading, HWPM and/or NAVSUP Afloat

Technician will inspect the container(s) and documentation(s), once all hazmat are approved excess hazardous material is offloaded from the ship and transported to the HWSA during normal operating hours. NAVSTA Rota does not provide transport. The designated ship personnel is responsible for arranging transportation from the pier to the HWSA.

4.6 TURN-IN OF EXCESS HAZARDOUS MATERIALS FROM

HOMEPORTED SHIPS

Homeported ships are required to designate an Afloat Environmental Protection Coordinator

(AEPC). The AEPC functions in a manner similar to the EVCs for ashore activities. When excess hazardous material requires offload and transfer to the HWSA, the AEPC follows the same procedure as outlined in section 4.3.3 for ashore activities associated with the preparation of turn-in documents. Once the turn-in documents are approved, NAVSUP Afloat

Technician is requested to come on-board to inspect the containers and documentation.

Once inspected and approved for turn-in, the AEPC arranges for offload of the excess hazardous material and transfer to the HWSA. Refer to appendix A for additional information.

NAVSUP Afloat Technician is requested to maintain hazmat offload documents.

Naval Station Rota, Spain 17

5 REPORTING AND RECORDKEEPING

5.1 SPANISH WASTE MANIFEST

A Spanish waste manifest (Hoja de Control y Seguimiento) is prepared by the DLA Disposition

Services HW contractor for each shipment of HW for disposal. The content of the manifest is verified during the loading of the waste at the HWSA. This manifest is reviewed and approved by the DLA Disposition Services HW COR before the HW disposal contractor is allowed to remove HW. The manifest will accompany all HW from NAVSTA Rota to its final destination, in accordance with Spanish Law.

At NAVSTA Rota, the Spanish Navy Fiscal Identification Number (NIF) is used as the Waste

Producer Identification Number by the Junta de Andalucía. The NIF is used for recordkeeping, reports and manifests for the management of waste.

Required manifest information includes:

• Generator’s name, address, and telephone number.

• Generator’s NIF.

• Transporter’s name, address, and telephone number.

• Destination, company name, address, and telephone number.

• Description of waste (physical state and waste code).

• Total quantity of waste.

• Date of shipment.

• Date of receipt.

The waste manifest process in Spain is illustrated in Figure 4-1 and the documentation and record-keeping requirement in the NAVSTA Rota are included in Table 4-1. The DLA HW

Contractor is required to send final and signed Spanish Waste Manifests to DLA HW COR and

HWPM.

Naval Station Rota, Spain 18

Source: Order 12 of July of 2002 of Junta de Andalucía

5.2 ANNUAL REPORTS

The HWPM submits annual reports to both the Junta de Andalucía and DoD. The report to the Junta de Andalucía is completed and submitted to the Spanish Base Commander for submittal to the regulatory agency. The annual report to the Navy (P2ADS) is submitted by the HWPM following the annual hazardous waste data call.

5.3 RECORDS RETENTION

NAVSTA Rota retains HW records in accordance with the requirements of Table 5-1.

Table 5-1: Records Retention Matrix

Record Time Retained Responsibility for Record Maintenance

Turn-in documents (e.g., DD1348-1A)

Five (5) years Department EV Continuity binders, DLA

Disposition Services HW COR, HWPM

Inspection Records

(Equipment, Containers and

Security)

Three (3) years from date of inspection

Responsible inspection parties: EVC, DLA

Disposition Services HW contractor, HWPM

Manifests Five (5) years DLA Disposition Services HW COR, HWPM

Waste Analysis/

Characterization Records

Three (3) years after closure of the HWSA

Department Continuity Binders, DLA

Disposition Services HW COR, HWPM

Waste profiles Three (3) years after closure of the HWSA

Department Continuity Binders, DLA

Disposition Services HW COR, HWPM

Waste

Generator Retain Delivery (

Certificate)

Transporter

HW Disposal Facility

Regional Environmental Agency

) Junta de Andalucía (

Provincial Office of

Regional

Environmental

Agency (Generation)

Provincial Office of

Regional

Environmental

Agency (Destination)

1 2 3

Numbered copies of manifest

Naval Station Rota, Spain 19

HW Log Five (5) years after last entry

DLA Disposition Services HW contractor

Training Records Five (5) years after termination of duty of personnel

Department Continuity Binders, HWPM

Junta de Andalucía Annual

Waste Report

Five (5) years HWPM

HW DoD P2ADS report Three (3) years HWPM

Naval Station Rota, Spain 20

6 TRAINING

Personnel assigned to duties involving actual or potential exposure to HW or excess hazardous materials must receive appropriate training prior to assuming those duties. Personnel assigned to these duties, including the EVC for ashore activities and the AEPC for homeported ships, shall work under direct supervision until the appropriate training is completed.

The training program ensures that facility personnel are able to respond effectively to emergencies, safely use equipment, and protect themselves from safety and health hazards associated with their assigned duties. Additionally, the training ensures that the assigned personnel understand accumulation and storage, inspections, transportation, and recordkeeping requirements. Training requirements are presented in Table 6-1.

Table 6-1: Training Requirements

All personnel at NAVSTA Rota

Hazardous Communication by Safety

EMS general awareness

EVCs/AEPCs

Introduction to the Hazcom

Overseas HW Facility Operator – initial and refresher

HSIRM – initial and refresher

HWSA Operator

Introduction to Hazcom

HSIRM – initial and refresher

Other HW courses as required by contract

HWPM

Naval Station Rota, Spain 21

7 CONTINGENCY PLAN

The NAVSTA PWD Environmental Division has implemented a spill prevention and pollution control

Program and maintains a Spill Prevention and Response Plan (SPRP).

7.1 SPILL PREVENTION AND RESPONSE PLAN

The prevention section of the SPRP provides information on responsible parties, inventory of storage/handling sites, inventory of petroleum, oil, and lubricants (POL) and hazardous substances, arrangements for emergency services and equipment, an evacuation plan, and written procedures for the prevention and reporting of POL and hazardous substance releases.

The spill control section of the SPRP provides responsibilities, procedures and responses to contain and clean up spills according to a classification scheme based on the type and amount of spilled material. A description of immediate response actions is provided along with the training requirements and procedures for Facility Response Team (FRT) alert and response. This section also includes provisions for coordination with the Facility Incident

Commander (FIC), Installation commander, emergency response manager, Spanish Navy, and regional Navy On-Scene Coordinator (NOSC), as appropriate. Clean-up methods, procedures and techniques to identify, contain, disperse, reclaim and remove POL and hazardous substances are outlined, as are procedures for reuse and disposal of recovered substances. Finally, this section provides details on those tasks to be accomplished prior to resuming normal operations at the site.

The reporting section of the SPRP addresses record-keeping and notification procedures. A copy of the plan is maintained at the PW Environmental Office by Spill Response

Coordinator.

7.2 POLLUTION PREVENTION AND WASTE

MINIMIZATION

Minimizing generation of HW is an important objective of Pollution Prevention (P2) at

NAVSTA Rota. P2 is a departure from years of end-of-the-pipe waste management practices and establishes a cradle-to-grave approach to waste management. The Pollution

Prevention Act of 1990, the primary driver behind P2 initiatives, encourages waste generators to adopt new principals guiding waste management practices. There is a hierarchy of waste minimization practices and management options to assist in the reduction and elimination of hazardous material use and waste generation. The hierarchy includes investigating source reduction as the primary means of reducing pollution, reviewing recycling alternatives after all source reduction options have been examined, considering treatment after recycling and source reduction has been deemed unfeasible, and using disposal only as the last resort after all other options have been exhausted.

Pollution Prevention and Waste Minimization is managed by NAVFAC EV Solid Waste & QRP

Recycling / Pollution Prevention Manager.

Pollution prevention at NAVSTA Rota focuses on planning for and evaluating the use of materials, processes, or practices in order to reduce or eliminate wastes at the source before they become an environmental concern as waste. The goal of P2 is to establish a long-term downward trend in the volumes of wastes generated and pollutants released to the environment. By achieving this goal, the costs resulting from reactionary waste management practices and dependence on hazardous materials use would also be greatly reduced.

NAVSTA Rota has implemented a P2 Plan that assists with the identification, evaluation, implementation, and tracking of P2 initiatives.

Additionally, NAVSTA Rota actively works to reduce waste generation at the source. The

Consolidated Hazardous Material Reutilization and Inventory Management Program

Naval Station Rota, Spain 22

(CHRIMP) contributes to the minimization of waste by reducing stored inventories of hazardous materials in the work centers. Hazardous materials are issued to base employees and the materials remaining after use are returned to CHRIMP for reuse by other departments. As a result of this reuse and sharing process, lesser quantities of hazardous materials are being ordered by multiple organizations and the potential for expired materials is reduced.

Hazardous Waste Management Plan Naval Station Rota, Spain 23

8 CLOSURE PLAN

This closure plan has been developed for the HWSA at NAVSTA Rota, Building 1811 to minimize or eliminate post-closure releases of HW, hazardous constituents, leachate, contaminated runoff, or HW decomposition products to the ground, surface water, or atmosphere. Closure refers to the de-commissioning of the HWSA and associated activities, including HW accumulation, storage, or disposal.

An entire installation does not have to be shut down to initiate closure. The “active portion” refers to that part of the installation where HW accumulation, treatment, storage, or disposal operations are conducted or have been conducted. This closure plan must be performed if any of the following situations occur:

• Use change of the HWSA at NAVSTA Rota, Building 1811.

• Use change of any section of the HWSA at NAVSTA Rota, Building 1811.

• Closure of the whole HWSA at NAVSTA Rota, Building 1811.

• Partial Closure of the HWSA at NAVSTA Rota, Building 1811

Following implementation of this closure plan, the Installation Environmental Program

Director will certify that the HWSA has been closed in accordance with the closure plan and applicable documentation will be forwarded to the Environmental Executive Agent for the closure file.

8.1 ESTIMATED HAZARDOUS WASTE STORAGE

CAPACITY

Hazardous waste storage at the HWSA is within Building 1811 and on the paved areas within its fence line. Solid HW may be stored directly on the paved areas, which liquid wastes are stored on secondary containment pallets or lockers located at compound. Hazardous waste are typically stored in single layer (i.e., not stacked on one another). The majority of HW kept in the facility is stored in 55-gallon or smaller DOT/ADR certified containers. The estimated storage capacity of the facility is 40,480 gallons, or 736, 55 gallon drums.

8.2 HAZARDOUS WASTE REMOVAL/GENERAL

DECONTAMINATION

All containers are sealed and labeled in Spanish and English prior to shipment. Following container removal through DLA Disposition Services, all foundations and drains will be washed down, and wash water will be contained until a sample is analyzed by a certified laboratory. If warranted, wash waters will be drummed and transported for proper disposal.

Facility decontamination will be performed by trained personnel. The services of these personnel will be obtained at the time of closure notification in accordance with contractual procedures established by NAVSTA Rota PWD Environmental Division or DLA Disposition

Services. Requirements for decontamination will be prescribed by contract and will require the contractor to provide all necessary equipment and protective clothing to safely complete decontamination.

Hand equipment used for decontamination will either be cleaned or discarded as regulated waste. Small items can be cleaned in containers with the wash water ultimately being added to drums for disposal. Larger equipment items can be cleaned in an area where the

Hazardous Waste Management Plan Naval Station Rota, Spain 24 wash water can be accumulated in a sump or trough. Wash water will be removed from the sump or trough and placed in drums for disposal.

Decontamination of the facility will be conducted under the supervision of PW Environmental

Division and trained technicians. During decontamination procedures, all personnel will wear the prescribed personal protective equipment. Prior to leaving the site, all personnel will remove and discard those items that cannot be cleaned for reuse, and the materials, including cleaning fluids, will be sealed in a container and transported offsite for disposal.

8.2.1 DECONTAMINATION OF NON-POROUS SURFACES

Following waste container removal, the HWSA must be decontaminated in order to obtain clean closure. Decontamination of non-porous surfaces associated with HW storage will be washed down, and wash water will be contained until a sample is analyzed by a certified laboratory. A detergent and/or steam cleaning may be used if necessary in order to remove surface contamination.

Verification sampling will be performed following decontamination. Wipe samples will be collected from all decontaminated surfaces.

8.2.2 DECONTAMINATION OF POROUS SURFACES

If wipe samples indicate that HW residues remain in porous surfaces, such as concrete, after initial decontamination, removal of all or part of these surfaces may be necessary. Naval

Station Rota NAVFAC PWD will determine which is more economically feasible: complete removal of the porous surfaces or removal of certain layers of the porous surfaces. The main goal will be to remove contamination in the most effective manner possible. If layers of porous surfaces are removed, wipe sampling of the remaining substrate will be conducted to verify that contaminants have been removed. Contaminated surfaces removed from the

HWSA will be disposed of as HW through DLA Disposition Services.

8.2.3 REMOVAL OF GROUND MEDIA

Hazardous waste is not generally stored on permeable surfaces (e.g., gravel, dirt), and the ground beneath the HWSA is paved. If NAVSTA Rota PWD Environmental Division personnel identify a potential area of contamination outside of the paved surfaces, soil samples will be collected and analyzed for possible HW constituents.

Contaminated soil, if small in quantity, will be removed with hand towels or shovels and placed in ADR-certified containers. These containers will be properly sealed, labeled in

Spanish and English, and disposed as HW through DLA Disposition Services. If larger quantities of soil require removal, appropriately sized mechanical equipment will be used to remove the soil and place it in a suitable covered removal container pending ultimate removal. Exact procedures will be determined by NAVFAC Environmental Division Director after sample analysis defines the extent of the contamination.

Soil samples will be taken at locations where there is evidence of spills or leaks. Background samples, in areas up-gradient from the HWSA, will also be collected. Downgradient samples will be obtained to evaluate any migration of contaminants from the HWSA. Soil samples will be collected at 20-foot intervals around the HWSA at a distance of 2 feet from the fence line and at a depth of up to 6 inches. Based on the results obtained from the analysis of the samples, additional analysis at additional locations may be required to define the extent of the contamination.

The entire site will be re-graded as necessary to prevent erosion subsequent to closure.

Hazardous Waste Management Plan Naval Station Rota, Spain 25

8.3 POSSIBLE CONTAMINANTS OF CONCERN

Given the variety of the waste types that are stored at the HWSA, wipe, wash water, and soil samples should be analyzed for the following constituents:

• Volatile organic compounds

• Semi-volatile organic compounds

• Toxicity (organic and inorganic)

8.4 EXPECTED CLOSURE DATE

The HWSA is not currently scheduled for closure.

Hazardous Waste Management Plan Naval Station Rota, Spain 26

9 REFERENCES

Naval Station Rota Pollution Prevention Plan.

U.S. Department of Defense, Final Governing Standards, Spain.

U.S. Department of Defense Directive 4160.21 series, “Defense Materiel Disposition Manual.”

Chief of Naval Operations Instruction. (2014, January 10). 5090.1D, Environmental

Readiness Program. OPNAV M-5090.1. Washington, DC: Department of the Navy.

Department of Defense. (2013, November 1). DoDI 4715.05, Environmental Compliance at

Installations Outside the United States. Department of Defense.

This page intentionally left blank

App…