NSASP_RWMP_DRAFT_FINALjs-rev(2).pdf

March 2017

FINAL

NSF Indian Head

NSF Dahlgren

Stump Neck Annex

Regulated Waste Management

Plan (RWMP)

Naval Support Activity

South Potomac i

Contents

Executive Summary ........................................................................................................................... iii

Record of Review and Summary of Changes ...................................................................................... iv

List of Acronyms ................................................................................................................................ v

1 – Regulated Waste Management Plan Administration

1.1 Purpose

1.2 Roles and Responsibilities

1.2.1 Naval Support Activity South Potomac

1.2.2 Installation Environmental Program Director (IEPD)

1.2.3 HW Program Managers

1.2.4 Solid Waste Performance Assessment Representative (SWPAR)

1.2.5 Recycling Program Manager

1.2.6 NSASP Fire Department

1.2.7 HW Operators

1.2.8 Supported and Supporting Commands, Tenants, and Contractor Personnel

1.2.9 NSASP Public Affairs Office

1.3 Contractor Operated Hazardous Waste Facilities

1.4 Points of Contact

2 – Regulatory Authority

2.1 Federal Facilities Compliance Act

2.2 Federal Regulations

2.2.1 Resource Conservation and Recovery Act

2.2.2 Department of Transportation

2.2.3 Occupational Safety and Health Administration

2.3 State Regulations

2.4 Navy Regulations

2.5 Permits

2.6 Enforcement

2.6.1 EPA Enforcement of Environmental Laws at Federal Facilities

2.6.2 State Enforcement Authority at Federal Facilities

2.6.3 Personal Liability

3 –Solid Waste

3.1 Hazardous Waste (HW)

3.1.1 Universal Waste

3.1.2 Explosive Hazardous Waste (EHW)

3.2 Non-Hazardous Waste

3.2.1 Controlled Waste

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3.2.2 Material Potentially Presenting an Explosive Hazard (MPPEH)

3.3 Recycling

4 – Hazardous Waste Management

4.1 Hazardous Waste Minimization

4.2 Hazardous Waste Generator Requirements

4.2.1 Hazardous Waste Determination

4.2.2 Hazardous Waste Characterization

4.2.3 Hazardous Waste Analysis

4.2.4 Declaring Unused Material Waste

4.2.5 Turn In of Excess Materials

4.3 Hazardous Waste Storage Requirements

4.3.1 General Requirements for ALL Hazardous Waste Storage Areas

4.3.2 Requirements Applicable to Satellite Accumulation Sites

4.3.3 Requirements Applicable to Less-than-90-day Storage Sites

4.3.4 Permitted Storage Sites - NSF Indian Head

4.4 Hazardous Waste Disposal Requirements

4.4.1 Turn in of Non-Explosive Hazardous Waste

4.5 Hazardous Waste Treatment Requirements

4.5.1 HW Treatment Operations Currently Permitted at NSASP

4.5.2 Emergency Treatment Operations

4.6 Hazardous Waste Training Requirements

4.6.1 Scope of Mandatory Training Requirements

4.6.2 Hazardous Waste Training Documentation

5 – Explosive Hazardous Waste and Waste Military Munitions (WMM)

5.1 Explosive Hazardous Waste

5.1.1 Storage of EHW

5.2 Treatment and Disposal of EHW

5.2.1 Subpart X

5.3 Waste Military Munitions

5.3.1 HW Determination

5.3.2 Military Munitions Rule

5.4 MPPEH

5.4.1 Material Documented as Safe (MDAS)

5.4.2 Material Documented as an Explosive Hazard (MDEH)

5.4.3 Disposal of MPPEH

6 – Universal Waste Management

7 – Emergency and Non-Emergency Procedures iii

7.1 HW Contingency Plans

7.1.1 Spills

7.1.2 Energetics

Appendix 1 – Definitions

Appendix 2 – Site Designation and Closure Forms

Appendix 3 – Example Waste Labels

Appendix 4 – Waste Turn-in Forms

Appendix 5 – Installation Specific HW Training

Tables

Table 1: WASTE MANAGEMENT POINTS OF CONTACT

Table 2: METHODS AND PROTOCOLS USED FOR COLLECTING REPRESENTATIVE SAMPLES

Table 3: CONTACTS FOR SPILLS/EMERGENCIES

Table 4: CONTACTS FOR SPILLS OF ENERGETIC MATERIAL

Executive Summary

Naval Support Activity South Potomac (NSASP) is committed to the proper management of waste including hazardous waste (HW), explosive hazardous waste (EHW), universal waste, and other regulated wastes generated within its boundaries. The primary objective of this Regulated Waste

Management Plan (RRWMP) is to assign responsibilities and explain procedures for the identification, collection, analysis, transportation, record keeping and disposal of HW and EHW generated at NSASP facilities: Naval Support Facility Indian Head (NSFIH), EPA ID: MD4170024109; including Stump Neck

Annex, EPA ID: MD4170090001; and NSF Dahlgren (NSFDL) including the Explosives Experimental Area, EPA ID: VAD7170024684.

This plan has been prepared in accordance with Department of Defense (DoD), Navy, Environmental

Protection Agency (EPA), Department of Transportation (DOT), Occupational Safety and Health

Administration (OSHA), Maryland Department of the Environment (MDE), and Virginia Department of

Environmental Quality (VDEQ) requirements. Compliance with this plan is mandatory and is applicable to all NSASP installation supported and supporting commands, tenants, and contractors.

The Naval Facilities Engineering Command Public Works Department Environmental Division (NAVFAC

PWD EV DIV), on behalf of the NSASP Commanding Officer, is responsible for preparing and updating this plan, providing oversight and technical support to NSASP and supported commands, tenants, contractors, managing all HW and EHW permits, and interfacing with Navy, DoD, state, and federal regulators.

Supported and supporting commands and activities are responsible for following the requirements in this plan; providing the NAVFAC PWD EV DIV with waste management data necessary for compliance;

treating, storing and disposing of waste in accordance with this plan; and ensuring that personnel with

HW management responsibilities are appropriately trained and capable of fulfilling their responsibilities.

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All contracting agencies are responsible for ensuring that contracts involving the use of hazardous materials (e.g., regional contract with Defense Logistics Agency Disposition Services (DLADS)) include specifications for providing proper management and disposal of wastes, oversight, and inspections of job sites where SW, HM and HW management is necessary. DLADS must monitor its waste disposal contracts to ensure that its contractors comply with all applicable regulations.

The NSASP Public Affairs Office (PAO) is responsible for managing all media inquiries related to hazardous and solid waste issues.

Record of Review and Summary of Changes

The RWMP shall be reviewed annually by the NAVFAC PWD EV DIV. The Record of Review and Summary of Changes provide a mechanism for documenting when and by whom the review occurred, as well as a summary of the changes made (when applicable).

Review Date Summary of Changes

Jun 2016 Updates included incorporation of solid waste in general and expansion of explosive/MDEH/ MPPEH/MDAS waste information, expansion of roles and responsibilities, update of PWD EV DIV point of contacts, update of references, and other minor text refinements.

Reviewer: Jeff Bossart Signature: Date:

Mar 2017 Updates included further clarification of processes related to Munitions Rule.

Incorporated EV comments and inserted updated site designation and turn-in forms.

Reviewer: Jeff Bossart Signature: Date:

Reviewer: Signature: Date:

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List of Acronyms

CFR Code of Federal Regulations

CHRIMP Consolidated Hazardous Material Reutilization and Inventory Management Program

CO Commanding Officer

DLADS Defense Logistics Agency Disposition Services

DoD Department of Defense

DOT Department of Transportation

EHW Explosive Hazardous Waste

EPA Environmental Protection Agency

ESAMS Enterprise Safety Applications Management System

FFCA Federal Facilities Compliance Act

FR Federal Register

HAZMINCEN Hazardous Material Minimization Center

HM Hazardous Material

HMR Hazardous Material Regulations

HW Hazardous Waste

ICO Installation Commanding Officer

IEPD Installation Environmental Program Director

MDAS Material Documented as Safe

MDEH Material Documented as an Explosive Hazard

MPPEH Material Potentially Presenting an Explosive Hazard

MDE Maryland Department of the Environment

MR Military Munitions Rule

NAVFAC Naval Facilities Engineering Command

NAVFAC PWD EV DIV NAVFAC Public Works Department Environmental Division

NAVFAC-Wash Naval Facilities Engineering Command Washington

NAVSEA Naval Sea Systems Command vi

NSASP Naval Support Activity South Potomac

NSFDL Naval Support Facility Dahlgren

NSFIH Naval Support Facility Indian Head

NSWCDD Naval Surface Warfare Center Dahlgren Division

NSWC IHEODTD Naval Surface Warfare Center Indian Head Explosive Ordnance Disposal Technology Division

OSHA Occupational Safety and Health Administration

PAO Public Affairs Office

PWD EV DIV Public Works Department Environmental Division

RCRA Resource Conservation and Recovery Act

SDS Safety Data Sheet

TSD Treatment, Storage, and Disposal

VDEQ Virginia Department of Environmental Quality

WMM Waste Military Munitions

RWMP Regulated Waste Management Plan

1 –Waste Management Plan Administration

1.1 Purpose

The purpose of this plan is to provide a framework for waste management including HW, universal waste, and other regulated wastes (e.g., used oil) at NSASP. Specifically, this plan provides NSASP military and civilian personnel with an environmental reference document to support overall waste management by defining responsibilities as generators relating to waste accumulation, storage, record keeping, training, emergency preparedness issues and additional responsibilities applicable to personnel involved in permitted and treatment operations. Definitions of key terms used in this RWMP are provided in Appendix 1.

This plan is applicable to all personnel on NSASP, which is comprised of NSFIH, Stump Neck Annex, and

NSFDL (including the Explosives Experimental Area complex). The personnel and operations covered by this plan include all supported and supporting commands, tenants, and contractors on NSASP that generate, store, treat, transport, or dispose of hazardous or other regulated waste. This plan can be used as a standalone plan for organizations and for supported commands and other tenants that do not have their own RWMP. Supported commands and tenants may develop and implement a command/tenant-specific RWMP that meets or exceeds the minimum requirements of the NSASP

RWMP.

1.2 Roles and Responsibilities

The roles and responsibilities of the commands and activities covered by this plan are summarized in this section. Listed responsibilities are not meant to be all inclusive.

1.2.1 Naval Support Activity South Potomac (NSASP)

NSASP retains ultimate authority and responsibility for all environmental permits and environmental compliance and readiness of the installation, including implementation of this RWMP, in accordance with OPNAV 5090.1D, Chapter 27, Paragraph 27-4.6. NSASP is responsible for ensuring installation compliance with all federal, state, and local regulations governing the generation, collection, treatment, storage, transportation, and disposal of SW, HW and EHW. NSASP shall:

Ensure that the solid and hazardous waste programs receive the appropriate level of attention to guarantee personnel are aware of and comply with the provisions of this RWMP.

Ensure that all tenants clearly identify who is responsible for planning, programming, and executing the resources needed to accomplish the annual requirements associated with RWMP implementation.

Ensure that on-scene command authority and overall responsibility for all spills at the facility are assigned to properly trained personnel.

1.2.2 Installation Environmental Program Director (IEPD)

The NAVFAC PWD IEPD, on behalf of the NSASP ICO, directs PWD EV DIV personnel and is responsible for researching, developing, and disseminating waste instructions and guidance, serving as the primary point of contact to regulatory agencies, and providing overall management of waste. The IEPD shall:

Ensure the RWMP is reviewed annually and any required updates are incorporated.

Ensure inspections of HW and EHW 90 day and 1 year accumulation, treatment, and storage, areas are conducted at least once annually for compliance with Resource Conservation and

Recovery Act (RCRA) regulations and permits.

Provide lead interface with state and federal regulators on all RCRA related matters and external inspections, and ensure appropriate coordination with supported commands.

Ensure appropriate RCRA permits are obtained, maintained and updated per the appropriate frequency.

Provide technical support to NSASP, supported and supporting commands and activities on RCRA-related matters such as waste classification, training, and regulatory interpretations.

Provide oversight of tenant, supported and supporting command and contractor-operated HW and EHW operating and storage areas.

Ensure correspondence, reports, plans and compliance documents are complete and submitted to the appropriate federal, state, and local regulatory agencies.

Provide emergency management support to the Fire Department and act as emergency coordinator, as required.

1.2.3 HW Program Managers

The NAVFAC PWD HW Program Managers oversee the HW and EHW program within their respective facilities. HW Program Managers shall:

Sign waste manifests as delegated in writing by the ICO.

Provide management and technical expertise to facilitate implementation of this RWMP.

Ensure all waste is properly characterized treated, stored, recycled or disposed of in accordance with all applicable environmental laws and regulations.

Conduct and document inspections of all regulated waste accumulation and storage areas in accordance with all federal, state, and local regulations and DoD and Navy requirements.

Promote waste reduction practices and coordinate with all offices and tenants to maximize recycling, reclamation, and reduction of waste products.

Ensure waste military munitions, are properly managed in accordance with the Military

Munitions Rule (MR) (62 FR 6621, February 12, 1997). Report any deviations from regulatory requirements in relation to waste storage, pickup, and transport to the IEPD.

Identify any deficiencies in EMSWeb, develop Plans of Action and Milestones and Corrective and Preventive Actions as necessary with the appropriate supported command, and monitor deficiencies until resolved.

Maintain all required records related to the hazardous waste program

Ensure waste manifests, shipping documents, disposal/treatment records are maintained on-site for a minimum of three years from the date the waste was treated on site or shipped off site to a TSDF . The Navy’s record retention requirement for HW disposal records is 50 years

(OPNAV 5090.1 (series)), but these records may be archived offsite for the remaining time.

1.2.4 Solid Waste Performance Assessment Representative (SWPAR)

The NAVFAC SWPAR falls under the Public Works Facilities Services Contracts (FSC) and shall:

Oversee the removal of municipal solid waste.

Ensure solid waste disposal contractors comply with the regional solid waste contract requirements.

Ensure waste collection complies with proper storage procedures.

1.2.5 Recycling Program Manager

The NAVFAC Recycling Program Manager is a regional position that falls under the Public Works FSC line.

The Recycling Program Manager shall:

Identify recyclable materials and ensure removal from the solid waste stream.

Oversee recycling contracts and the sale of recycled materials.

1.2.6 NSASP Fire Department

As part of their responsibilities, the NSASP Fire Department shall:

Review and participate in the development of emergency action plans.

Play an active role in the development and implementation of contingency plans.

Perform table top exercises and conduct drills of Emergency Response per contingency planning.

Assume the initial role of Incident Commander during response to RCRA-related emergency management of HW or hazardous material (HM).

Perform duties as first responder and contain HW or HM spills, and coordinate with EV for disposal and reporting

Review construction projects at the design stage.

1.2.7 HW Operators

HW Operators shall manage hazardous waste (including explosive waste and universal waste) and used oil in accordance with all applicable federal, state, and local regulations as well as Navy and NSASP policies and instructions. Responsibilities include, but are not limited to:

Comply with the requirements of this RWMP and any applicable waste contracts.

Perform onsite waste pickup/transport/labeling/recordkeeping, manage HW accumulation/storage areas, and coordinate waste shipments in accordance with this plan and any activity specific HW procedures.

Inspect all HW accumulation/storage areas and correct any deficiencies identified during inspections.

Report any deviations or potential issues that may lead to a deviation from regulatory requirements to the IEPD and HW Program Manager.

Ensure personnel with HW and EHW management responsibilities meet the minimum training requirements identified in Section 4.6.

1.2.8 Supported and Supporting Commands, Tenants, and Contractor Personnel

The responsibilities of supported and supporting commands, tenants, and contractor personnel include:

Implement requirements of this RWMP for classification, characterization, accumulation and turn-in of waste.

Provide information to the NAVFAC PWD EV DIV in order to obtain and comply with RCRA permits.

Manage HW and EHW treatment, storage, and accumulation areas in accordance with this plan and any activity-specific waste management plans (if applicable).

Ensure personnel with waste management responsibilities meet the minimum training requirements identified in Section 4.6 of this plan, and that training certifications are readily available.

Provide supporting data concerning HW and EHW operations to the NAVFAC PWD EV DIV for regulatory and Navy reporting.

Ensure HW manifests are signed only by designated HW Program Manager(s).

As generators of waste within NSASP, implement practices to reduce waste generation and disposal.

1.2.9 NSASP Public Affairs Office

The NSASP PAO shall:

Act as the focal point for inquiries from the news media and concerned citizens regarding all waste issues.

Assist the NSASP ICO during situations involving HW or EHW incidents by keeping interested news media and the public aware of events and curtailing rumors through the dissemination of coordinated, accurate information. The PAO may respond to the accident/incident site, command post, and PAO duty section where an information center may be established.

1.3 Contractor Operated Hazardous Waste Facilities

NAVFAC is the primary contracting organization responsible for the proper operation, transportation, storage, and disposal of non-explosive waste on NSASP.

To the maximum extent feasible, all HW should be processed through NSASP HW facilities operated by

NAVFAC contractors in accordance with regional contract requirements, this RWMP, any other applicable procedures. HW turn-in procedures are provided in Section 4.4.

Any customer service issues that arise associated with analysis/transportation/storage/disposal of waste should be addressed directly to the appropriate NSASP points of contact. See Table 1 for contacts and phone numbers.

1.4 Points of Contact

The NAVFAC points of contact for waste management at NSASP are listed in Table 1.

Table 1: WASTE MANAGEMENT POINTS OF CONTACT

Line Organization Title Phone

Environmental NSASP Installation Environmental Program

Director 301.744.4705

Environmental NSFIH Environmental Compliance Branch

Manager 301.744.1616

2 – Regulatory Authority

2.1 Federal Facilities Compliance Act

The Federal Facilities Compliance Act (FFCA) was enacted by presidential proclamation in 1992. This law expands the enforcement authority of federal, state, and local regulators with respect to hazardous waste management and other relevant areas of environmental compliance at federal facilities. The FFCA requires the payment of fees for service, assessed in connection with hazardous waste regulatory inspection programs, or for the amount of hazardous waste generated at the facility. This act also waives government sovereign immunity, allowing regulatory agencies to issue fines and penalties for violations on issues of non-compliance.

2.2 Federal Regulations

Federal regulations published by the United States EPA are found in Title 40 of the Code of Federal

Regulations (CFR), DOT regulations are found in Title 49, and OSHA regulations are found in Title 29.

New and proposed federal regulations are published in the Federal Register (FR), which is published daily, except for official holidays. The FR provides a uniform system for making available to the public regulations and legal notices issued by federal agencies.

2.2.1 Resource Conservation and Recovery Act

RCRA regulates the management of solid waste, hazardous waste and underground storage tanks used for petroleum products and certain chemicals. RCRA requires EPA to promulgate and enforce regulations regarding HW management. These regulations, which can be found in 40 CFR Parts 260 -

266, 268, 270 - 273, 279, and 280 - 282, establish the mandatory procedures and requirements for compliance and must be followed by all Navy facilities that accumulate, transport, treat, store, and/or dispose of HW, universal waste, and other regulated waste.

2.2.2 Department of Transportation

Because all RCRA HW is also a DOT HM, the HW must be handled, prepared, and transported in accordance with DOT Hazardous Materials Regulations (HMR). The HMR are developed by the Research

Environmental NSFDL Environmental Compliance Manager 540.653.5071

Environmental NSFIH HW Program Manager 301.744.2268

Environmental NSFDL HW Program Manager 540.284.4392

Public Works NSFIH Solid Waste Performance Assessment

Representative 301.744.4269

Public Works NSFDL Solid Waste Performance Assessment

Representative 540.653.5764

Public Works Region Recycling Program Manager 202.433.0929 and Special Programs Administration within DOT to provide for the safe transport of HM in commerce.

The HMR are contained in 49 CFR Parts 171 -180.

2.2.3 Occupational Safety and Health Administration

OSHA regulates the safety and health of workers in the United States by establishing and enforcing worker protection standards that employers must follow. OSHA has promulgated standards to protect workers engaged in HM and HW operations and emergency response activities. These standards are found in 29 CFR 1910.120, 1910.1200, and 1910.1450.

2.3 State Regulations

RCRA allows each state to establish and enforce its own HW management program, provided that the state’s requirements are no less stringent than the federal rules. Both Maryland and Virginia are authorized by EPA to develop, implement, and enforce HW regulations. The Virginia HW management regulations are found in 9 Virginia Administrative Code 20-60. Maryland regulations are found in the

Code of Maryland Regulations 26.13.01 - 26.13.13.

2.4 Navy Regulations

The Environmental and Natural Resources Manual, OPNAV M-5090.1 (Series) provides requirements, responsibilities and policies for management of the environment and natural resources for Navy ships and shore activities. Chapter 27 of OPNAV 5090.1 identifies requirements and responsibilities for waste management at Navy shore facilities.

The regulations for the safe storage, handling, use of, and explosive safety for munitions are found in

Naval Sea Systems Command (NAVSEA) OP 5 Volume 1 (Ammunition and Explosives Ashore: Safety

Regulations for Handling, Storing, Production, Renovation, and Shipping), DoD 6055.9-STD (Ammunition and Explosives Safety Standards), and DoD 4160.28-M-1 (Defense Demilitarization Manual). The regulations found in NAVSEA OP 5 Volume 1 take precedence for explosives safety when there is a conflict between RCRA and NAVSEA OP 5.

2.5 Permits

Hazardous waste permits for NSFIH and NSFDL are listed below.

NSF Dahlgren:

o Part B Permit: U.S. Navy Hazardous Waste Management Storage Permit, EPA ID No.

VA7170024684

o Subpart X Permit: Final Permit for the Thermal Treatment of Hazardous Waste by Open

Burning and Open Detonation, EPA ID No. VA7170024684

NSF Indian Head:

o Part B Permit: Controlled Hazardous Substance Facility Permit, Permit No. A-223, integrating Interim Subpart X Permit Application for 40 CFR, Subpart X, Miscellaneous

Units, EPA ID No. MD4170024109 o Part B Permit: Controlled Hazardous Substance Facility Permit, Permit No. A-223a (Stump

Neck), EPA ID No. MD4170090001 o Interim Subpart X Permit Application: NAVEODTECHDIV Part B, Permit Application for 40

CFR Subpart X, Miscellaneous Units, Application (Stump Neck), EPA ID No. MD4170090001.

2.6 Enforcement

Procedures available to regulatory agencies for the enforcement of environmental laws at federal facilities are described in this section.

2.6.1 EPA Enforcement of Environmental Laws at Federal Facilities

The FFCA requires federal facilities to comply with all federal, state, interstate, and local solid and HW management and disposal requirements. It requires compliance, both substantive and procedural, in the same manner and to the same extent, as any other entity that is subject to such requirements. The

FFCA also amends section 6001 of RCRA to clarify that the United States waives any sovereign immunity for the impositions of civil or administrative fines and penalties.

Federal employees are not liable for civil penalties under federal or state solid or HW law for any act or omission within the employee’s scope of official duties. However, the federal employee may be subject to criminal penalties.

EPA monitors compliance status and identifies violations at Navy installations by reviewing reporting documents and conducting onsite inspections. Once a violation is discovered, EPA makes a determination of noncompliance and may take an initial enforcement action. A Notice of

Noncompliance or Notice of Violation will generally be issued by EPA as the initial enforcement action.

Such notification indicates to the regulated entity that the enforcement agency believes that the entity is in violation of the law and that it must come into compliance or be prepared to defend its actions in subsequent enforcement. These alleged violations do not represent a final, legal determination that a violation has occurred until adjudication is complete.

2.6.2 State Enforcement Authority at Federal Facilities

RCRA enables EPA to delegate to a state the authority to enforce the HW management regulatory program. Therefore, each state with authorization has inspection, enforcement, remedy, and penalty programs in place. Both Maryland and Virginia are authorized to administer RCRA. States may pursue bilateral, negotiated agreements or Consent Orders with federal facilities.

If HW is not managed in accordance with state statutory or regulatory requirements, the authorized state has several options available to enforce compliance, including administrative and civil actions.

2.6.3 Personal Liability

If an item is a HW, it must be managed as a HW in accordance with RCRA. If an individual knowingly fails to manage HW properly and violates RCRA, that individual is personally liable for any and all legal actions (fines and/or imprisonment) taken against him/her.

Report all violations to the NAVFAC PWD EV DIV immediately so appropriate action may be taken.

Facility points of contact are listed in Table 1.

Actions that can lead to criminal penalties and fines include:

Transporting or causing the transportation of HW to a non-permitted facility;

Treating, storing, or disposing of HW without a permit or in violation of a condition of a permit or interim status standard;

Falsifying manifests, labels, or other required documents;

Concealing or destroying any documents required to be retained or filed;

Transporting HW without a manifest;

Exporting waste without the consent of the receiving country; and

Transporting, treating, storing, disposing of, or exporting any HW such that another person is placed in imminent danger of death or serious bodily injury.

3 – Solid Waste A solid waste is any garbage, refuse, sludge (from wastewater or water treatment plants or an air pollution control facility), and other discarded material (including solid, liquid, semisolid, or containerized gaseous material) from industrial, commercial, mining, and agricultural operations, and from community activities. Military munitions are considered solid wastes when they are abandoned, disposed, incinerated/burned, rendered nonreusable or nonrecyclable, declared a waste by an authorized military official, or used/detonated and collected for storage, recycling, treatment, or disposal.

Some materials are excluded from the definition of solid waste by Congressional action or EPA rulemaking. Solid waste does not include solid or dissolved material in domestic sewage and irrigation return flows, or industrial discharges that are point sources subject to permits, radioactive wastes, or byproduct materials listed in 40 CFR section 261.4(a).

NSASP follows the Integrated Solid Waste Management requirements described in OPNAV 5090.1D

Chapter 28, and implements, where applicable, the Integrated Solid Waste Management hierarchy of source reduction, diversion, and as a last resort, disposal of solid waste generated in support of Navy's mission.

3.1 Hazardous Waste (HW)

A HW is a solid waste which because of its quantity, concentration, or physical, chemical, or infectious characteristics may lead to at least one of the following effects:

Cause or significantly contribute to an increase in mortality, or an increase in serious irreversible or incapacitating reversible illness.

Pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.

Section 4 of this RWMP reviews HW management and requirements in greater detail.

3.1.1 Universal Waste

Universal wastes are a type of HW (batteries, pesticides, mercury containing equipment, and lamps) that can be easily managed or exhibit lower level hazards. They are subject to more streamlined regulations than other types of HW to facilitate proper disposal and promote recycling. Section 6 of this RWMP reviews the requirements associated with Universal Waste.

3.1.2 Explosive Hazardous Waste (EHW)

Explosive material becomes a waste if it is no longer intended to be used, reused, recycled, or recovered. EHW is a HW that is known or suspected to present an explosion hazard. Section 5 of this

RWMP reviews EHW and associated requirements in greater detail.

3.2 Non-Hazardous Waste

Non-hazardous waste is a solid waste that is neither hazardous nor controlled. Municipal solid waste includes everyday items discarded by the public (commonly known as “trash” or “garbage”) that are non-hazardous and able to be disposed in a municipal landfill. Municipal solid waste can be disposed of in the standard garbage dumpsters located near most buildings throughout NSASP.

Municipal solid waste comprises the majority of solid waste managed at NSASP and does not include solid wastes from industrial, medical, or sewage operations. Examples of municipal solid wastes include food wastes, discarded recyclable materials (paper, cans, bottles, metals, etc., which should be placed in the proper recycled containers), chemically inert material such as cured liners for rocket motors, packing material that cannot be reused, and rags with small amounts of controlled wastes (rags may not contain any amount of HW and may not be saturated to the point of dripping/leaking).

3.2.1 Controlled Waste

Controlled wastes are non-hazardous wastes that cannot be disposed of with general trash. Examples include oils and some solvents. Toxic Substances Control Act (TSCA) regulated materials such as asbestos are also considered controlled wastes. Containers storing controlled wastes must be marked with the words “Non-Hazardous Waste” along with a name identifying the waste. Controlled wastes cannot be placed into unlined landfills where they could migrate into stormwater or mix and react with other wastes in the landfill. All controlled waste must be disposed of through the NSFIH or NSFDL

Environmental Office . All controlled wastes must be accompanied by a Hazardous Material/Hazardous

Waste Turn-In Form, Safety data sheet (SDS), and/or chemical analysis.

3.2.2 Material Potentially Presenting an Explosive Hazard (MPPEH)

MPPEH is material that is not known with certainty to present an explosive hazard, but may contain explosive material (e.g., brass, fiber, and plastic containers from training ranges). MPPEH is considered non-hazardous and includes material that has come in direct contact with explosives and has only a trace amount of propellant, explosives, or pyrotechnic contamination. Refer to Section 5.3 for more information on MPPEH.

3.2.3 Material Documented As Safe (MDAS)

MDAS is MPPEH that has been assessed and documented as not presenting an explosive hazard and for which the chain of custody has been established and maintained. This material is no longer considered to be MPPEH. Only qualified individuals may declare MPPEH a material documented as safe (MDAS) through specific procedures and methods detailed in Naval Sea Systems Command, NAVSEA OP 5, Ammunition and Explosives Safety Ashore.

3.3 Recycling

Green procurement and recycling is utilized whenever possible. Tenants must participate in their host facility’s recycling program, and only authorized materials as per state or local regulation and OPNAV 5090.1D Chapter 28 shall be recycled.

4 – Hazardous Waste Management This section outlines standards applicable to management of all hazardous wastes, explosive and non-explosive. Standards specific to explosive hazardous waste management are outlined in greater detail in

Section 5.

4.1 Hazardous Waste Minimization

NSASP is committed to implementing the Navy’s policy of reducing the volume of hazardous waste generated and disposed of during all missions and operations. The facility prioritizes the elimination of

HW at the source, and any operations involved in the generation of HW must include all possible source reduction strategies including those related to requirements, processes, equipment, and materials.

Other HW minimization strategies include (in order of decreasing priority):

Substituting HM with a less hazardous or non-hazardous material .

Recycling/recovery/reuse of the HM.

Reducing/eliminating excess and expired HM.

Treatment of the HW to reduce its volume or convert it to a less hazardous state.

Destruction of the HW and EHW

Disposal of the HW (must remain a last resort).

These strategies should be considered and enacted, whenever possible, and can be combined and integrated within operations to achieve maximum HW reduction.

4.2 Hazardous Waste Generator Requirements

4.2.1 Hazardous Waste Determination

Once a material, substance, or residue is discarded, abandoned, or is no longer usable for its intended purpose, it becomes classified as a waste. If the waste meets the definition of solid waste as defined in 40 CFR 261, it must then be evaluated to determine if it is a characteristic or listed hazardous waste.

4.2.2 Hazardous Waste Characterization

Waste characterization is the identification, description, and quantification of a waste stream. It is important that wastes be properly characterized to ensure proper control and timely disposal. Each HW generator is responsible for ensuring that wastes are properly characterized prior to disposal. This includes identifying all waste sources and requesting appropriate analysis.

Characteristic Wastes

A characteristic HW must exhibit at least one of the four characteristics of ignitability, corrosivity, reactivity, or toxicity. The HW is assigned at least one EPA HW number (ranging from D001 to D043) based on the characteristic(s) it exhibits. This number must be used to comply with notification, recordkeeping, and reporting requirements.

Characteristic of Ignitability

A waste that exhibits the characteristic of ignitability is assigned the HW number of D001. In order to be ignitable, a representative sample of the waste must have at least one of the following properties:

It is a liquid, other than an aqueous solution containing less than 24% alcohol by volume, and has a flash point less than 60°C (140°F), as determined by an appropriate test method. Testing requirements are described in Section 4.2.3 of this plan.

It is not a liquid and, under standard temperature and pressure, can cause fire through friction, absorption of moisture, or spontaneous chemical changes; and when ignited, burns so vigorously and persistently that it creates a hazard.

It is an ignitable compressed gas as determined by appropriate test methods.

It is an oxidizer. An oxidizer is a substance such as chlorate, permanganate, inorganic peroxide, or a nitrate, that yields oxygen readily to stimulate the combustion of organic matter.

Characteristic of Corrosivity

A waste that exhibits the characteristic of corrosivity is assigned the HW number of D002. In order to be corrosive, a representative sample of the waste must have at least one of the following properties:

It is aqueous and has a pH of 2 or less, or 12.5 or greater, as determined by appropriate test methods.

It is a liquid that corrodes steel (SAE 1020) at a rate greater than 6.35 millimeters (0.250 inch) per year, at a test temperature of 55°C (130°F), as determined by appropriate test methods.

NOTE: HW Program Managers may provide assistance with HW determination and characterization, which need to be performed according to established federal, state, local, DoD and Navy procedures prior to being processed through applicable NSASP HW accumulation/storage buildings. Unknown wastes must be managed as hazardous until analytical results are obtained.

Characteristic of Reactivity

A waste that exhibits the characteristic of reactivity is assigned the HW number of D003. In order to be reactive, a representative sample of the waste must have at least one of the following properties:

It is normally unstable and readily undergoes violent change without detonating.

It reacts violently with water.

It forms potentially explosive mixtures with water.

When mixed with water, it generates toxic gases, vapors, or fumes in a quantity sufficient to endanger human health or the environment.

It is a cyanide- or sulfide-bearing waste that can generate toxic gases, vapors, or fumes in a quantity sufficient to endanger human health or the environment when exposed to pH conditions between 2 and 12.5.

It can detonate or explode if subjected to a strong initiating source or heated under confinement.

It can readily detonate or explode at standard temperature and pressure.

It is a forbidden explosive or is a Division 1.1, 1.2, or 1.3 explosive.

Characteristic of Toxicity

A waste that exhibits the characteristic of toxicity is assigned at least one HW number ranging from

D004 through D043. In order to be characteristically toxic, an extract from a representative sample must contain one or more of the contaminants listed in Table 1 of 40 CFR 261.24, at a concentration at least as high as the listed value.

Listed Hazardous Wastes

A HW is listed if it is specifically named in federal and/or state regulations. In listing materials as HW, EPA considers factors such as the toxicity, reactivity, corrosivity, and ignitability potential of the waste.

Listed HW are classified as F-listed, K-listed, P-listed, or U-listed. F-listed wastes are wastes from non-specific sources and are described in 40 CFR 261.31. K-listed wastes are generated from specific sources and are described in 40 CFR 261.32. P-Listed and U-listed wastes are discarded commercial chemical products, manufacturing chemical intermediates, off-specification commercial products, or materials mixed with such wastes. Both P- and U-lists are found in 40 CFR 261.33.

HW is also classified as acute or non-acute. Wastes on the P-list and certain dioxin numbers (F-020-F023, and F-026-F028) are considered to be acute, whereas the remaining numbers are considered non-acute.

NOTE: If the waste is not considered a HW under RCRA, it should be reviewed to determine proper disposal of the material, which may include contacting the disposal facility to ensure that the material being disposed is an accepted material or if additional documentation is required (e.g., Special Waste Disposal Request form). Universal wastes (e.g., fluorescent lamps, batteries) and even some non-HW (e.g., used oil and asbestos) are still regulated for proper disposal. If in doubt as to how to classify a waste, contact your HW Program Manager for assistance.

4.2.3 Hazardous Waste Analysis

All operators must characterize wastes either by testing in accordance with methods specified by EPA in the appendices to 40 CFR 261 or by applying generator knowledge of the hazardous characteristics of the materials or processes used. Waste analyses may be required by EPA or the authorized state if the constituents of the waste stream are unknown, if HW characteristics are unknown, or if the waste is subject to land disposal restrictions.

The EPA publication, SW-846, entitled, Test Methods for Evaluating Solid Waste Physical/Chemical

Methods provides test procedures and guidance for making waste determinations. After performing the

HW determination and characterizations, the generator must properly treat, store, recycle or dispose of the waste in accordance with all applicable environmental laws and regulations.

Waste samples will be collected in accordance with EPA-specified procedures identified in Table 2.

These procedures ensure that the collected samples are representative of the waste stream.

Table 2: METHODS AND PROTOCOLS USED FOR COLLECTING

REPRESENTATIVE SAMPLES

Waste Type Protocols

Extremely viscous liquids ASTM Standard D140-70

Crushed or powdered material ASTM Standard D346-75

Soil or rock-like material ASTM Standard D420-69

Soil-like material ASTM Standard D1452-65

Fly ash-like material ASTM Standard D2234-76

Containerized liquid wastes EPA SW-846 COLIWASA Procedure

Liquid wastes in pits, ponds, lagoons, and similar reservoirs EPA SW-846 Pond Sampler

4.2.4 Declaring Unused Material Waste

Generators are responsible for determining the usability of hazardous materials. In some cases, although hazardous materials may have exceeded manufacturers recommended shelf life, the materials may still be useful for testing or research and development. However, once any energetic or non-energetic hazardous material is of no further use, it must be declared a waste and either treated or stored as required.

4.2.5 Turn In of Excess Materials

NSASP supported and supporting commands should be participating in the NSASP Consolidated

Hazardous Material Reutilization Inventory Management Program (CHRIMP).

A primary objective of CHRIMP is to reduce the generation of HW through the tracking of hazardous materials from their point of issue to their disposal. Under this program, partially empty and completely empty HM containers are accounted for and are required to be turned back in to the issuing Hazardous

Material Minimization Center (HAZMINCEN) after usage.

NSASP supported and supporting commands shall:

Utilize the HAZMINCEN for hazardous material procurement requirements to the maximum extent whenever possible.

Provide oversight and management for all hazardous materials in use or storage at work centers.

Maintain accountability of all HM and HM containers.

Define authorized work centers and material.

4.3 Hazardous Waste Storage Requirements

4.3.1 General Requirements for ALL Hazardous Waste Accumulation and Storage Areas

Submit a site designation form to the facility HW Program Manager prior to opening a new HW storage site. The HW site designation form is included in Appendix 2.

Designate a certified site manager for each hazardous waste storage site.

Use containers that are in good condition and that close properly.

Ensure that wastes covered under the RCRA Subpart X regulations (e.g., wastes from open burn/detonation) are never mixed with other HW.

Use containers made of or lined with materials that are compatible with the HW to be accumulated.

Mark HW containers with the words "Hazardous Waste", a name that clearly identifies the contents of the container and the accumulation start date. Note that HW containers in Satellite

Accumulation Areas do not need to be marked with the accumulation start date until the container is full. Examples of hazardous waste labels are included in Appendix 3.

ATTENTION: There are numerous explosive safety requirements that must be followed for proper accumulation and storage of EHW. Supporting and supported commands and tenants generating

EHW waste shall provide amplifying guidance to their personnel managing less-than-90-day and satellite accumulation sites for EHW. The requirements below are the minimum RCRA requirements that must be followed for all HW generated on NSASP.

In accordance with the Generator Improvement Rule, each HW container must be marked or labeled with an indication of the hazards of the contents. Examples include, but are not limited to:

o Applicable hazardous waste characteristics (ignitable/flammable, corrosive, reactive toxic).

o Hazard communication consistent with DOT labeling or placarding (49 CFR part 172 subpart E or F).

o Hazard statement or pictogram consistent with OSHA Hazard Communication Standard

(29 CFR 1910.1200) or United Nations Global Harmonized System (GHS).

o NFPA Code 704 Chemical Hazard Label.

o Containers in one year storage must also be labeled with all applicable EPA Waste

Codes.

Do not place incompatible wastes in the same container. Do not place wastes in a container that previously held an incompatible waste or material.

Keep all containers closed, except when adding or removing waste. Do not open, handle, or store the container in a manner which may rupture the container or cause it to leak.

Provide secondary containment for all liquid wastes.

Locate all ignitable or reactive HW a minimum of 50 feet from the facility's property line.

Provide weather protection for any secondary containment systems to prevent the accumulation of rain/snow/debris in the containment.

Site HW containers that are located outside and holding only solid wastes (no free liquid) in an area that is sloped (or otherwise designed) to drain and remove liquid precipitation.

Separate incompatible wastes by a physical barrier to prevent the mixing of the wastes due to a spill.

Do not store non-HW with HW in a secondary containment system without providing additional means of physical separation in the event of a spill or release.

Fill each container to no more than 95% of its maximum capacity to allow room for expansion.

ATTENTION: Incompatible wastes shall not share the same secondary containment system without a physical barrier to separate them.

Maintain and operate the storage site to minimize the possibility of a fire, explosion, or any unplanned release of HW which could affect human health or the environment.

At closure, all HW and residues must be removed from the containment system. Submit a site closure form to the facility HW Program Manager. The HW site closure form is included in

Appendix 2.

4.3.2 Requirements Applicable to Satellite Accumulation Sites

Do not accumulate more than 55-gallons of HW or 1 quart of acute HW at the satellite accumulation site.

Use the date the container becomes full (not to exceed 95% of its design capacity) as the accumulation start date.

Keep all containers closed, except when adding or removing waste. Do not open, handle, or store the container in a manner which may rupture the container or cause it to leak.

Provide secondary containment for all liquid wastes.

Move full containers from the satellite accumulation area to an appropriate storage area (a less than 90 day storage area or a one (1) year storage area) or send the waste for treatment within three (3) calendar days of the accumulation start date.

4.3.3 Requirements Applicable to Less-than-90-day Storage Sites

Inspect each less-than-90-day storage site at least weekly.

Within 90 days of the accumulation start date, move the waste to a permitted storage site, ship off-site, or send the waste for treatment.

Ensure all non-explosive HW less-than-90-day storage sites are equipped with the following:

o A telephone or pull alarm, immediately available to a person at the site capable of calling for emergency assistance;

o An alarm system (e.g. pull boxes) at the site that is capable of calling for emergency assistance;

o Spill control/containment equipment (e.g. sawdust or absorbent booms/pigs);

o Fire protection (e.g. portable fire extinguishers (non-explosive sites only), fire suppression system);

o Adequate aisle space to allow unobstructed movement of personnel and spill control equipment; and o Water at adequate pressure and volume for firefighting.

Post a sign at the entrance of each accumulation area stating, "DANGER ALL UNAUTHORIZED

PERSONNEL KEEP OUT".

RCRA-empty containers in less-than-90-day sites should be labeled or marked with the word

“EMPTY” unless a designated area is used to store empty containers. All other markings must be removed or painted over.

4.3.4 Permitted Storage Sites for Non-Explosive Hazardous Waste (non-EHW) - NSF Indian Head

NSFIH maintains a long-term (one year) RCRA Part B permitted container storage area for non-EHW in

Building 455. HW in Building 455 is removed and disposed of by a licensed disposal contractor. HW must be properly manifested and documented. Containers must receive all necessary marking and labeling in accordance with DOT, OSHA and EPA requirements.

4.4 Hazardous Waste Disposal Requirements

4.4.1 Turn in of Non-Explosive Hazardous Waste

The following steps must be performed prior to turning waste in for disposal:

GENERATOR

Characterize waste – Prior to turning in non-EHW for disposal it must be properly characterized. Proper characterization is necessary to ensure that hazardous waste transporters and treatment, storage and disposal facilities can safely transport and dispose of the waste. Characterization and/or analysis of waste is described in Section 4.2.

Once a waste is characterized, a waste turn in sheet must be completed and submitted with a

Safety Data Sheet (SDS) or chemical analysis. An example turn in sheet is included in Appendix 4.

HW CONTRACTOR (with oversight of HW Program Manager)

Prepare a waste profile sheet and DD1348-1 based on information provided on the waste turn in sheet…