TE A-20_ENV_USAG ST HWMP_2024_Signed.pdf

USAG STUTTGART

HAZARDOUS WASTE MANAGEMENT PLAN

(HWMP)

- - - FINAL - - -

Update February 2024

APPROVALS

This hazardous waste management plan (HWMP) satisfies the requirement contained in Chapter 10-1. Hazardous Waste of the Army Regulation 200-1 (Dec 2007), to develop and implement a HWMP that includes, at a minimum, written procedures for all aspects of hazardous waste (HW) management, to include the identification, storage and transporting of HW, training of personnel, tracking manifests and maintaining required records. Furthermore, this HWMP satisfies the requirement to develop and maintain a Closure Plan contained in Section C6.3.3.11.2 and a Waste Analysis Plan in Section C6.3.3.3.1 of Chapter 6, Hazardous Waste, of the German Final Governing Standards (GFGS).

Approved by:

G. Kirk Alexander Date

COL, FA

Commanding

Approved by:

Marisa K. Barrie Date Director of Public Works

USAG Stuttgart

Prepared by:

Therese Mundorff Date DPW, Environmental Division

HAZARDOUS WASTE MANAGEMENT PLAN

RECORD OF REVISIONS

This HWMP must be reviewed annually and updated at least once every five years. The following table is provided for tracking revisions to this plan.

Revision No. Date Description Pages Affected

1 Jan 2016 DPW-ED staff revision Approvals, Page 1-2, Page 4, A1-1, A1-2, A4-1, A4-2, A6-1, A9- 1, A9-2, Appendix 10, 2 Feb 2018 DPW-ED staff revision Approvals, Page 4, A9-2

3 December

HWMP update by Wood with approval thru DPW-ED staff

Entire document

4 February

DPW-ED staff revision Approvals, Pages: 1- 1,2-2,9-1,2,10-1,2

5 February

HWMP update by Tetra Tech with approval of DPW-ED staff

Approvals, Page 3-5, 5-1, 6-2, 7-2, 9-1, A1-1, A1-2, A1-4, A1-5, A1-9, A5-5

A7-1, A7-2 i

TABLE OF CONTENTS

SECTION PAGE NUMBER

1. Introduction ................................................................................................................ 1-1

2. Key Personnel ............................................................................................................ 2-1

2.1 Waste Management Officer (Betriebsbeauftragter für Abfall) ............................... 2-1

3. Storage and Accumulation ....................................................................................... 3-1

3.1 Containers (incl. HWCONs) ...................................................................................... 3-1

3.2 Hazardous Waste Batteries (incl. HWBATs) ........................................................... 3-2

3.3 HWAP .......................................................................................................................... 3-2

3.4 HWSA .......................................................................................................................... 3-3

3.4.1 General Requirements ....................................................................................... 3-3

3.4.2 Security Systems ................................................................................................ 3-4

3.4.3 Closure ................................................................................................................ 3-4

3.5 Aboveground Storage Tanks ................................................................................... 3-4

3.6 Underground Storage Tanks .................................................................................... 3-5

3.7 Used Oil ...................................................................................................................... 3-5

3.8 Inspections ................................................................................................................. 3-6

4. Training ....................................................................................................................... 4-1

5. Transportation ........................................................................................................... 5-1

5.1 Off-Post Transportation Procedures ....................................................................... 5-1

5.2 On-Post Transportation Procedures ....................................................................... 5-1

6. Disposal ...................................................................................................................... 6-1

6.1 DLA-Contract ............................................................................................................. 6-1

6.2 Tendering of Hazardous Waste ................................................................................ 6-1

6.3 Hazardous Waste Identification ............................................................................... 6-1

6.4 Waste Streams ........................................................................................................... 6-1

7. Documentation ........................................................................................................... 7-1

7.1 Hazardous Waste Disposal Documentation ........................................................... 7-1

7.2 Monthly Status report (MSR) and Yearly Status Report (YSR) ............................. 7-1

7.3 Manifests .................................................................................................................... 7-1

8. Contingency plans ..................................................................................................... 8-1

9. References.................................................................................................................. 9-1 ii

APPENDICES

Appendix 1 List and locations of HWSA, HWAPs, HWBATs, HWCONs, and Waste Oil Tanks

Appendix 2 Sample Container Label

Appendix 3 State-Specific Requirements

Appendix 4 HWSA Closure Plan

Appendix 5 Example Inspection Checklists and Forms

Appendix 6 Hazardous Substances Compatibility Chart

Appendix 7 Hazardous Waste Training Guidance

Appendix 8 Hazardous Waste Management Compliance Plan

Appendix 9 Hazardous Waste Audit Trail Instructions

Appendix 10 Hazardous Waste Analysis Plan

LIST OF TABLES

Table 1-1 HWMP Regulatory Cross Reference Matrix ..................................................... 1-1

Table 2-1 Hazardous Waste Activities that require a Waste Management Officer ........... 2-1

Table 2-2 Key Personnel ................................................................................................... 2-2

Table 3-1 HWSA approved by the German Authorities .................................................... 3-3

Table 7-1 Recordkeeping .................................................................................................. 7-2

Table A-1.1.1 List of HWAPs ............................................................................... Appendix 1

Table A-1.1.2 List of HWBATs ............................................................................ Appendix 1

Table A-1.1.3 List of HWCONs ........................................................................... Appendix 1

Table A-1.2 List of HWSA .................................................................................... Appendix 1

Table A-1.3 List of Waste Oil Tanks .................................................................... Appendix 1

Table A-3.1 Hazards levels based on volume and Water Hazard Class ............. Appendix 3

Table A-4.1 Regular HW Streams ....................................................................... Appendix 4

Table A-6.1 Hazardous Substances Compatibility Chart..................................... Appendix 6

Table A-7.1 Hazardous Waste Training Guidance .............................................. Appendix 7

Table A-8.1 Hazardous Waste Management Compliance Plan .......................... Appendix 8 iii

ACRONYMS

AER Army in Europe Regulation

ADR European Agreement Concerning the International Carriage of Dangerous Goods by Road

AR Army Regulation

ASF Abfallsammelbehälter für flüssige Sonderabfälle (waste collection container for liquid hazardous wastes)

AST Aboveground storage tank

AwSV Verordnung über Anlagen zum Umgang mit wassergefährdenden Stoffen (German Ordinance on installations for handling substances hazardous to water)

CFR Code of Federal Regulations

COR Contracting Officer Representative

DLA Defense Logistics Agency

DoD Department of Defense

DPW Directorate of Public Works

ED Environmental Division

EO Environmental Officer

EPAAS Environmental Performance Assessment and Assistance System

GFGS Final Governing Standards for Germany

HAZCOM Hazard Communication

HM Hazardous Material

HW Hazardous Waste

HWBAT Container for collection of household batteries

HWCON Container for collection of cooking oil

HWAP Hazardous Waste Accumulation Point

HWMP Hazardous Waste Management Plan

HWPS Hazardous Waste Profile Sheet

HWSA Hazardous Waste Storage Area

IMCOM-E Installation Management Command - Europe

IBC Intermediate Bulk Container

LGK Lagerklasse (storage class)

O&M Operation and Maintenance

OEBGD Overseas Environmental Baseline Guidance Document

OSHA Occupational Safety and Health Administration

PPE Personal Protective Equipment

POC Point of Contact

POL Petroleum, Oil and Lubricants iv

SDS Safety Data Sheet

SOP Standard Operation Procedure

SPRP Spill Prevention and Response Plan

SWMP Solid Waste Management Plan

TRGS Technische Regeln für Gefahrstoffe (Technical Rules for Hazardous Substances)

U.S. United States

USAG United States Army Garrison

UST Underground storage tank

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1. INTRODUCTION

This HWMP has been developed for current and planned hazardous waste (HW) generation and disposal activities. The Directorate of Public Works (DPW) Environmental Division (ED) is responsible for development, maintenance, and implementation of this HWMP.

Throughout this HWMP, all subsequent citations from the German Final Governing Standards (from September 2020) are simply referred to as the "GFGS". In addition, it should be noted that the nomenclature for GFGS section numbers includes a reference to both the GFGS chapter and paragraph (e.g., GFGS, Ch. C6.2.2. refers to Chapter 6, Paragraph 6.2.2). In addition, references to the German Ordinance on installations for handling substances hazardous to water (AwSV - Verordnung über Anlagen zum Umgang mit wassergefährdenden Stoffen) will be referenced as applicable. Short excerpts of the most relevant paragraphs of the AwSV are presented in Appendix 3. This Ordinance came into force in Germany in August 2017 and the requirements will be implemented in the GFGS with the next update (expected in November / December 2020)

The purpose of a HWMP is to outline policies and procedures for proper handling, storage, and disposal of HW. Chapter 6 of the GFGS contains cross-references to Chapter 5, Hazardous Materials (HM), and Chapter 7, Solid Waste.

The HWMP should be used in combination with the Garrison’s Solid Waste Management Plan (SWMP) for effective overall management of waste generated. The SWMP is managed by the Operation and Maintenance (O&M) Division.

Regular inspections of Hazardous Waste Accumulation Points (HWAPs), containers for collection of household batteries (HWBATs), containers for collection of cooking oil (HWCONs), Hazardous Waste Storage Areas (HWSAs), and tank systems storing HW, must be performed to assess compliance with the provisions of this HWMP. The sample compliance plan table in Appendix 8 may be used to facilitate this process.

Table 1-1 HWMP Regulatory Cross Reference Matrix

Hazardous Waste Management Plan (HWMP)

German FGS Chapter Description

Applicable Section of

HWMP

Remarks

C6.3.1. Hazardous Waste Generators 7.1

C6.3.2 HWAPs 3.3

C6.3.2.5 Personnel Training for Managing HWAPs 4

C6.3.3 HWSA 3.4

C6.3.3.11 Closure and Closure Plans for HWSA 3.4.3/

Appendix 4

C6.3.4 Container Handling and Storage 3.1

C6.3.4.4 Special Requirements for Incompatible Wastes Appendix 6

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Hazardous Waste Management Plan (HWMP)

German FGS Chapter Description

Applicable Section of

HWMP

Remarks

C6.3.5 Recordkeeping Requirements 7

C6.3.6 Contingency Plan 8

C6.3.7 Tank Systems 3.5 & 3.6

C6.3.8 Management of Used Oil and Batteries 3.2 & 3.7

C6.3.10 Hazardous Waste Training 4/ Appendix 7

C6.3.11 Hazardous Waste Disposal 6

C6.3.12 Permitted Transportation and Disposal Companies

C6.3.13 Appointment and Responsibilities of Waste Management Officer

2.1

C6.3.16 Daily Removal of Hazardous Waste to HWAP or HWSA

3.3

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2. KEY PERSONNEL

2.1 WASTE MANAGEMENT OFFICER (BETRIEBSBEAUFTRAGTER FÜR ABFALL)

The United States Army Garrison (USAG) Stuttgart has appointed Ms. Therese Mundorff as the primary Hazardous Waste Manager (Betriebsbeauftragte für Abfall). The activities defined in the host nation laws that require a Waste Management Officer (according to GFGS C6.3.14) are applicable for the Garrison with regards to HW storage facility and hospital and/or clinic (see Table 2-1).

Table 2-1 Hazardous Waste Activities that require a Waste Management Officer

Hazardous Waste Activity Yes No

Hazardous waste storage facility x

Hazardous waste disposal facility x

Landfill x

Incinerator x

Hospital and/or clinic x

Plant for chemical or physical treatment of hazardous waste with a throughput of more than 0.5 metric tons (500 kg) per hour x

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Table 2-2 Key Personnel

Position/Task Unit/

Activity Name

DSN

Phone

E-mail Address

Garrison Hazardous Waste Manager

DPW-ED Prim.:

Therese Mundorff

Alt.:

Simone Leiss- Wenzel

596-6135

596-6134 therese.mundorff.ln@army.mil simone.leiss-wenzel.ln@army.mil

Point of Contact (POC) for HW Training DPW-ED

HWSA Manager Management of HW disposal contracts Maintenance/update of disposal documentation

DPW-ED

Maintenance of Training Documents

Generating unit

Unit EO/ Training Officer

Unit POC

Unit POC

Maintenance of Hazardous Waste Audit Trail Documents

Generating unit

Unit EO/ Unit POC for HW

Unit POC

Unit POC mailto:therese.mundorff.ln@army.mil mailto:simone.leiss-wenzel.ln@army.mil mailto:therese.mundorff.ln@mail.mil mailto:therese.mundorff.ln@mail.mil

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3. STORAGE AND ACCUMULATION

The USAG Stuttgart currently operates 22 HWAPs, 22 HWBATs, 6 HWCONs, one HWSA, and 10 Waste Oil Tanks. The DPW ED personnel are primarily responsible for the overall setup and maintenance of the HWAPs and the HWSA. Individual appointed Unit Environmental Officers (EO) and Environmental Representatives of activities are responsible for assisting in the HW management at the workforce level. Appendix 1 contains a list of the active HWAPs, HWBATs, HWCONs, the HWSA and the Waste Oil Tanks and the associated units/activities.

3.1 CONTAINERS (INCL. HWCONS)

Container requirements apply to both the general storage practices and container labeling. The following container requirements are to be followed at the USAG Stuttgart. (GFGS, Ch. C6.3.4.)

• All containers used to collect HW at HWAPs and the HWSA must be approved in accordance with The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR).

• Containers holding HW must be in good condition and free from severe rusting, bulging, or structural defects (GFGS, Ch. C6.3.4.1.1.).

• Containers used to store HW, including overpack containers, must be compatible with the materials stored (GFGS, Ch. C6.3.4.1.2.).

• A container holding HW must always be closed during storage, except when it is necessary to add waste (GFGS, Ch. C6.3.4.1.3.1.).

• A container holding HW must not be opened, handled, or stored in a manner which may rupture the container or cause it to leak (GFGS, Ch. C6.3.4.1.3.2.).

• Containers of flammable liquids must be electrically grounded when transferring flammable liquids from one container to the other (GFGS, Ch. C6.3.4.1.3.3.).

• Containers holding HW must be marked with a HW marking and a label indicating the hazards of the waste contained therein (flammable, corrosive, etc.), as appropriate (GFGS, Ch. C6.3.4.1.4.).

• Areas where containers are stored must be inspected weekly for leaking and deteriorating containers, as well as deterioration of the containment system caused by corrosion or other factors. Secondary containment systems must be inspected for defects and emptied of accumulated releases or retained stormwater (GFGS, Ch.

C6.3.4.1.5.).

• All hazardous waste containers must have appropriate labels indicating the waste stream, and other required information. Example labels are provided in Appendix 2.

• Areas that store containers holding ignitable or reactive wastes must be located at least 15 meters (50 feet) inside the installation’s boundary.

• Incompatible wastes (see Appendix 6) must be stored in segregated containers and must not share secondary containment structures. Where necessary, incompatible wastes must be physically separated using berms, dikes, walls, or other similar means.

• Containers are property of a contractor firm and must be handled in an orderly manner and only used for storing the designated waste streams.

• Secondary containment systems must be compatible to the accumulated waste and must be impervious to contain leaks or spills. Rainwater captured in containments must be inspected before release.

Locations of the containers placed for collection of cooking oil (HWCONs) are presented in Appendix 1. HWCONs must fulfill the general requirements of HW containers listed above.

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3.2 HAZARDOUS WASTE BATTERIES (INCL. HWBATS)

Storage of used batteries shall only be conducted at sites with impervious surfaces and appropriate weatherproofed cover or in appropriate containers. This also applies if used batteries are stored only temporarily. Lead-acid batteries, nickel-cadmium batteries and batteries containing mercury must be managed as HW, regardless of whether they are to be recycled or disposed of permanently. The layers of lead-acid batteries and other car batteries in the container should be separated by using cardboard paper. The poles of lithium batteries should be taped to avoid contacts with each other.

Locations of the containers placed for collection of household batteries (HWBATs) are listed in Appendix 1. HWBATs must fulfill the general requirements of HW containers listed under Section 3.1 of this HWMP.

3.3 HWAP

A HWAP is defined as a location where HWs are accumulated until removed to a HWSA or transported for treatment or disposal. A HWAP is used to accumulate ≤ 208 liters (≤ 55 gallons) of HW per waste stream, or 1 liter (1 quart) of acute HW per each waste stream (GFGS, Ch.

C6.2.18). Wastes intended to be recycled or used for energy recovery (e.g., used oil or antifreeze) are excempt from the accumulation limit but must be transported offsite to a final destination facility within 1 year (GFGS, Ch. C6.3.2.2.). The HWAP must be located at or near the point of generation and under the control of the operator (GFGS, Ch. C6.2.18).

Locations of the HWAPs are indicated on the list presented in Appendix 1. All HWAPs, as listed in Appendix 1, are to be operated in accordance with the following standards (GFGS, Ch.

C6.3.2, C6.3.4):

• All containers in HWAPs must be handled in accordance with the provisions stated in Section 3.1 of this HWMP.

• Personnel assigned HW duties must successfully complete HW training (see Section 4 of this HWMP).

• A single container must be provided for the collection of each waste stream. Chemically incompatible wastes must be segregated accordingly. Sufficient volume must be left in containers storing liquids, so the contents can expand with increases in temperature.

• Each HWAP must have hazard signs appropriate for the waste being accumulated at that site (GFGS, Ch. C6.3.2.1).

• The HWAP must be kept secured and/or locked to avoid uncontrolled disposal of waste from unauthorized persons.

• A spill kit containing proper equipment to respond to spills must be maintained at a

HWAP.

• The Garrison Red Plan must be posted at a HWAP.

• Small amounts of hazardous waste generated daily must be collected at the point of generation (i.e., in the shop bays) in proper containers and must be moved or emptied into larger containers, at a designated HWAP, on a daily basis.

• The HWAP must be kept clean and orderly. Accumulation of Solid Waste, and HW not properly containerized, is not allowed.

• The access area must be kept free at all times. “No Parking” signs must be posted to provide free access for the waste removal contractor and the Fire Department in case of an incident.

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• A sufficient number of fire extinguishers must be available where flammable waste is stored. Fire extinguishers must have a valid inspection sticker.

• Hazardous materials (HM) storage is not allowed at a HWAP. All hazardous substances placed at a HWAP are treated as waste for disposal.

• HWAPs should be inspected weekly by the Unit EO or Environmental Representative of the generating unit by using a checklist (see Appendix 5).

• Generating Unit must notify the Garrison HW Manager of Containers 75 % full.

• HW Audit Trail documents (see Section 7) are maintained at the generating unit for at least 3 years.

3.4 HWSA

3.4.1 General Requirements

A HWSA is defined as a location on a DoD installation where HW is collected and stored prior to shipment for treatment or disposal. HWSAs are permitted to store more than 208 liters (55 gallons) of each waste stream and more than 1 liter (1quart) of an acute HW stream.

The HWSA at USAG Stuttgart (see Table 3-1) is considered an ordinary or conventional facilitiy;

and therefore, requires a construction approval or test of suitability (Bauartzulassung oder Eignungsfeststellung) from the German authorities. The test of suitability was already performed prior to delivery.

Table 3-1 HWSA approved by the German Authorities

ARLOC Facility No.

Construction Approval (Yes/No)

Suitability Test

(Yes/No)

Approving German Authority

Approval Date

GE44F 3371 Y Y

Landesumweltamt

Nordrhein- Westfalen

04.12.1998

The HWSA is located at building 3371 and operated in accordance with the following standards (GFGS, Ch. C6.3.3, C6.3.4, C6.3.5):

• The HWSA that is used for storage of water endangering substances is not located in an area that is classed as Water Protection Zone I or II.

• The HWSA is not located in an area prone to flooding. The HWSA is secured against floating and shifting, and the area is designed such that water cannot enter vent pipes, filling ports or other inlets in the event of flooding. Additionally, the HWSA is resistant to mechanical damage from flooding.

• The HWSA is designed and must be operated to minimize the possibility of fire or unplanned release of HW that could threaten human health or the environment.

• HW must not be stored longer than one year at the HWSA.

• Aisle spaces in the HWSA must be sufficient to allow movements of personnel, vehicles and equipment during an emergency. Exit ways must be kept free at all times.

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• An emergency phone, Personal Protective Equipment (PPE), eye-wash solution and an emergency shower must be available at the scene of operation. The emergency devices will be tested during regular inspections (see Section 3.8).

• Mobile fire extinguishers are installed at three strategic locations at the HWSA.

• Secondary containments are provided for the HWSA that is classified as Water Hazard Category C facility. The secondary containments are designed to retain 100 % volume of the largest container or 10 % of the total volume stored, whichever is greater.

• Rainwater captured in secondary containments must be inspected visually prior to release. If this inspection indicates a potential for contamination or if the nature of the hazardous waste stored is such that this inspection is not acceptable, the potentially contaminated water is submitted for laboratory testing prior to release.

• In addition, all containers in the HWSA must be handled in accordance with the provisions stated in Section 3.1.

• A HWSA is also operated in accordance with HWAP requirements listed under Section 3.3.

3.4.2 Security Systems

The HWSA is secured against unauthorized entry by a fence completely surrounding the area and a locked gate equipped with warning signs (incl. “No Smoking” and “Unauthorized Access forbidden”), hazard signs and mandatory signs both in English and German language.

3.4.3 Closure

A Closure plan has been prepared for the HWSA and is presented in Appendix 4. Additional closure plans for new HWSAs will be prepared during the HWSA planning stages, including estimates of the storage capacity of hazardous waste, steps to be taken to remove or decontaminate all waste residue, and an estimate of the expected closure date.

3.4.4 Waste Analysis Plan

A Waste Analysis Plan prepared by the Garrison HW Manager is presented in Appendix 10.

3.5 ABOVEGROUND STORAGE TANKS

The USAG Stuttgart installations have no aboveground storage tanks (ASTs) that store liquid hazardous waste in quantities that fall under the notification or permit requirement to the German Federal State (GFGS, Ch. C5.3.15). According to the German AwSV, the competent authority must be notified in writing at least six weeks in advance when an installation subject to inspection is constructed or substantially altered. No notification is required for installations that need to conduct an assessment of suitability or applications for BImSch approval (AwSV §40).

A certified removal company, contracted for disposal of HW, provides the required collection containers, including waste collection containers for liquid hazardous wastes (Abfall-Sammel- Behälter für flüssige Sonderabfälle – ASF) with up to 1,000 liters capacity or Intermediate Bulk Containers (IBC) with up to 1,000 liters capacity. The containers are tested, certified for transportation on roads, and labelled by the UN-Markings. The liquid level in the containers must be shown by a fill level indicator or must be visually controlled to ensure the filling process is stopped before the acceptable filling level is reached.

Government-owned aboveground waste oil collection tanks >1m3 must be regularly inspected by an authorized expert (zugelassener Sachverständiger). The following tank-specific

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• Tank specifications, such as size, contents, and construction type, are clearly indicated on each AST.

• Tank storage areas have secondary containment systems that is sufficiently impervious or capable of holding and contain leaks and spills of liquid or solid hazardous waste.

• In addition, all requirements outlined in Section 3.1 also apply to tank systems storing hazardous waste.

3.6 UNDERGROUND STORAGE TANKS

The USAG Stuttgart installations uses underground storage tanks (USTs) for collecting waste oil. A list of the USTs is provided in Appendix 1.

All USTs that store waste oil must be inspected by an authorized expert (zugelassener Sachverständiger, e.g., TÜV) prior to their initial use to obtain an operating permit. Each UST must be inspected by an authorized expert every five years after the initial inspection to refresh the operating permit. In case the UST is located in a water protection area, the inspection must be performed every 2.5 years (GFGS Section C5.3.14.3.). According to the German AwSV, these inspection periods will remain unchanged (AwSV §46 and Appendix 5 & 6).

Additionally, expert inspections will be conducted under the following conditions:

• When significant modifications to the facilities are made,

• If the competent German authority issues an inspection request due to a suspected threat to water bodies,

• After decommissioning a facility, and

• After the re-commissioning or re-opening of a facility that has been closed for more than one year.

During normal facility operations UST inspections must be performed on a yearly basis by an authorized expert to include checking of the operating and leak detection systems. The inspection reports must be provided to the ED.

Problems identified during the inspections need to be addressed to the ED as appropriate.

Deficiencies that are imminently dangerous to human health and the environment (such as alarm system failures) must be reported to the ED immediately.

Records of the UST inspections must be entered to the tanks logbook and shall be maintained for at least three years at the ED. Additionally, the results shall be entered into the applicable Database of the ED.

3.7 USED OIL (MOTOR/ENGINE)

Whenever possible, processing of used oil is given priority over burning used oil for energy recovery or otherwise disposing of used oil. In general, used oil fuel may be burned in facilities that have a permit issued by the appropriate German authorities, but no used oil is burned at USAG Stuttgart. Used oil, HW, or used oil contaminated with any HW will not be used for dust suppression or road treatment.

Used cooking oil must be collected and disposed of separately through the DPW Recycling Center.

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3.8 INSPECTIONS

Unit Inspections

The EO or Environmental Representative of a HW generating unit has to perform internal weekly inspections of the HWAP by using appropriate checklists. If a waste oil tank is used, daily inspections of the tank facility is required. Appendix 5 provides example checklists that may be used to perform internal inspections.

Any non-compliance that cannot be resolved by the HW generating unit must be reported to the ED immediately. Any deficiencies of containers where a potential release of hazardous waste may occur or any malfunctions of the waste oil tank control systems must be reported to the ED immediately.

If the acoustic alarm of the waste oil tank is turning on, the unit is allowed to turn off the acoustic alarm followed by immediate reporting of the failure to the ED. Self-repairs at the waste oil facility are prohibited.

ED Inspections

The ED HW manager and/or assigned contractor personnel conducts on-site environmental inspections as required throughout the year. Usually these inspections will also include areas other than Hazardous Waste. The results of the inspections will be recorded by using the checklists provided in Appendix 5. The ED will conduct re-inspections as needed to verify the completion of corrective actions.

The ED performs once a year an Internal Environmental Performance Assessment and Assistance System (EPAAS) audit. The findings of the audit will be recorded and reported to the IMCOM-E Environmental Division by using a shared database. The progress of corrective actions of findings will be tracked by the ED.

Appointments for the inspections and the audit will be made in advance with the EO or Environmental Representative.

Besides the schedules, units are also encouraged to request courtesy inspections at the ED.

External Inspections

The IMCOM-E Environmental Division performs every three years an external Environmental Performance Assessment and Assistance System (EPAAS) audit. The audits will be performed by IMCOM-E representatives and will take 5 days. The audit will cover all environmental medias.

The results of the audit will be summarized and presented to the Garrison Commander and his staff, and to the unit representatives during an out-brief conference. The findings will be tracked in an IMCOM-E shared database. The progress of corrective actions of findings will be tracked by the DPW ED on a regular basis.

The DPW ED will inform all stakeholders of the EPAAS schedule in advance.

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4. TRAINING

All personnel who are involved in handling, storage, and disposal of hazardous waste must receive appropriate training before executing work duties involving exposure to hazardous waste. At the minimum, a First Responder Awareness Training (Level I) must be given verbally, by a trained employee, to all persons working with hazardous waste prior to initiating work.

Appendix 7 provides an example form used to document training.

All personnel performing hazardous waste duties must complete an initial 40-hour OSHA Training. The Environmental Officer (EO) must complete an initial 40-hour EO Training.

Personnel who have completed the initial EO or OSHA training must perform an 8-hour refresher training annually. The ED may be contacted for EO training updates.

The OSHA and EO training programs include sufficient information to enable personnel to perform their assigned tasks while complying with HW requirements. Personnel are instructed in the following key areas:

• Emergency Procedures: response to fire/explosion/spills; use of communications/alarm systems, emergency equipment and emergency systems; body and equipment clean-up;

• Safe use of hazardous waste equipment: drum/container handling/storage;

• Employee Protection: PPE, safety and health hazards, hazard communication, worker exposure to HS; and,

• Recordkeeping, security, inspections, contingency plans, storage requirements, transportation requirements.

Training courses, attendees, and dates of completion are documented and tracked by the ED HW Manager for the time of assigned duty. All relevant training documents shall be kept at the responsible unit office for the time of assigned duty and at least three years after the termination of duty of these personnel.

Appendix 7 provides guidance on required training by activity and general position description.

Training opportunities for Hazardous Waste Management and for Spill Response Training can also be requested at the ED HW Manager.

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5. TRANSPORTATION

5.1 OFF-POST TRANSPORTATION PROCEDURES

All off-post transportation of HW must be performed only by permitted transportation companies. All other off-post transportation of hazardous waste is strictly prohibited. The ED HW Manager must verify that contracted companies fulfill the requirements and own all necessary licenses and approvals to transport dangerous goods on road, according to the ADR.

Tenant Units or other activities that have approved personnel, licenses and vehicles capable to transport dangerous goods are NOT automatically allowed to transport HW, too.

HW must not be transported outside the installation boundaries from units or other activities.

5.2 ON-POST TRANSPORTATION PROCEDURES

The transportation of hazardous waste on-post is performed according to the following procedures:

• Hazardous waste must be only transported by ADR trained personnel who have the proper transportation vehicles and equipment, and transport HW only in limited quantities (max. 55 gallon / 208 Liter, or 1-liter [1-quart] of acute hazardous waste).

• Vehicles must be in good condition, have sufficient storage space, enough carrying capacity, and provisions to secure loads.

• Appropriate material handling equipment must be used to load, transport, and unload containers. This equipment includes drum dollies, forklifts, drum handling equipment, lift gates, and pallets. Drums must not be rolled on or off vehicles.

• Loads must be properly placed on vehicles. Hazardous waste containers must be placed and secured in stable positions. The containers must not be placed such that they overhang, perch, or lean.

• Loads must be secured with straps, clamps, braces, or other measures to prevent movement and loss. Forklifts must not be used to transport drums and containers that are not secured.

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Page 6-1

6. DISPOSAL

The HW must be collected at the Garrison at designated HWAPs until final removal through a waste removal company to dispose of its HW in appropriately permitted facilities.

The EO or the responsible person of each HWAP must request pick-ups at the ED upon detection of 75 % full containers. The ED performs the required documentation and scheduling with the removal contractors.

6.1 DLA-CONTRACT

The Garrison contracts through the Defense Logistics Agency (DLA) located at Kaiserslautern, Germany. The ED HW Manager, as a representative of the DLA, collects pick-up requests and prepares and stores the required documentation which will be submitted to the DLA. The DLA will then provide a Delivery Order and within 14 days the pick-up will be performed by German transportation contractors for disposal off-base at host nation disposal facilities in accordance with German regulatory requirements. The HW Manager signs the acceptance slip (Übernahmeschein) when the HW is picked-up by the contractor.

HW must not be transported to the DLA from tenant units and other organizations as off-post transport is strictly prohibited (see Section 5.1), and the DLA has no permitted facility to store hazardous waste.

Attempts to turn-in HW at the DLA from units will be rejected and the HW must be transported back to the Garrison.

6.2 TENDERING OF HAZARDOUS WASTE

Hazardous Waste shall be tendered to the Sonderabfallagentur Baden-Wuerttemberg in accordance with the specific waste disposal regulations of Baden-Wuerttemberg.

The tendering is performed by the contracted certified waste disposal company on behalf of the Garrison as the HW generator.

6.3 HAZARDOUS WASTE IDENTIFICATION

The ED HW Manager maintains Hazardous Waste Profile Sheets (HWPSs) for each hazardous waste stream generated at the Garrison. Each HWPS will be updated und submitted to the DLA annually.

6.4 WASTE STREAMS

The following waste streams can be disposed under the current contracts:

Acids

Adhesive, Glues

Aerosol cans

Antifreeze

Asbestos containing items

Bases

Batteries dry-cell, lithium, Nickel-Cadmium, lead-acid

Compressed Gas Cylinders

Contaminated containers, metal

Contaminated containers, plastic

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Page 6-2

Detergent, liquid and solid

Fire extinguisher and residues

Gas Cartridges

Grease

Heavy metals, heavy metal contaminated solids and liquids

Laboratory chemicals

Light tubes and lamps

Paints

PCB containing items

Pesticides, liquid, solid, aerosols

POL contaminated filters

POL contaminated solids

Printer cartridges

PU-foam aerosols

Solvents

Waste fuel

Waste oil (Motor/Engine oils)

The following items cannot be disposed under the current contract:

Ammunitions

Arms and weapons

Biohazard materials

Explosives

Radioactive materials

Tires*

Used Cooking Oil*

*Should be turned into the DPW Recycling Yard for disposal

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Page 7-1

7. DOCUMENTATION

The ED maintains an audit trail for hazardous waste disposal from the point of generation to ultimate disposal. The records are maintained for at least 3 years at the ED (see Table 7-1).

7.1 HAZARDOUS WASTE DISPOSAL DOCUMENTATION

All hazardous waste disposed under the current contracts (DLA-contract) are tracked and recorded at the ED.

The documentation includes:

• Acceptance slips and Manifests (Übernahmescheine und Entsorgungsnachweise)

• Delivery Orders and Modifications

• 1348-1A Forms

• Pick up Checklists

• Delivery slips and invoices

• Relevant correspondence

HW generating units are responsible to manage their own HWAP and must maintain a Hazardous Waste Audit Trail for hazardous waste disposal from the point of generation to final disposal (GFGS C6.3.1.4.3). Appendix 9 describes detailed instructions.

7.2 MONTHLY STATUS REPORT (MSR) AND YEARLY STATUS REPORT (YSR)

The waste removal company contracted through DLA provides monthly reports of the HW removed from the Garrison. Additionally, the company provides a yearly report of the waste removals sorted by building numbers. The status reports include all HW related data from the point of generation to the final disposal or recycling facility.

7.3 MANIFESTS

The manifests contain the following information:

• Name and address of the hazardous waste generator;

• Hazardous waste generator number (Abfallerzeugernummer);

• Transporter’s name and address;

• Destination name and address;

• The six-digit EWL (European List of Wastes) code of the hazardous waste stream;

• Total quantity of waste in metric tons;

• Date of shipment;

• Date of receipt by the destination facility;

• Container number and size;

• Waste description according to ADR;

• Contract and item number;

• CLIN number;

• Manifest number.

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Page 7-2

Table 7-1 Recordkeeping

Record Time maintained Location where record is maintained

Hazardous Waste Disposal Documentation (incl. YSR, MSR, Contract documentation)

5 years, or until the transfer of surveillance documentation to the Contracting Officer upon completion of the contract

ED (Contracting Officer Representative (COR))

Hazardous Waste Log (FGS-G C6.3.5.2)

Until Closure of Installation ED (HW manager)

Internal inspection Checklists for HWSA (FGS-G C6.3.3.8) and Waste Oil UST (see Section 3.6)

3 years ED (HW manager)

External Inspection documents for systems requiring inspection according to German legislation

As long as the system is being used

At the place of operation

HW Audit trail documents, Inspection checklists

3 years Unit level (EO)

Training documentation 3 years after termination of employment

Unit level (EO, Training Officer)

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Page 8-1

8. CONTINGENCY PLANS

The USAG Stuttgart has developed a Spill Prevention and Response Plan (SPRP) that describes how to respond to spills and releases of hazardous substances, including hazardous waste. Part of the SPRP is the Red Plan that serves as an immediate action tool to initiate the correct response at the earliest possible time. The Red Plan must be posted at all locations, where a potential release of hazardous waste or hazardous substance could occur.

Chapter 1.1.2 of the SPRP describes the sections that may be used to develop a Contingency Plan.

The HWSA, the on-site Fire Department, the on-site hospitals, and any emergency response teams identified in the plan must be provided with a copy of the SPRP. Updates must be forwarded to these organizations as appropriate.

HWAP Managers must maintain a copy of the HWMP and the SPRP. Each HWAP must be provided with copies of the Red Plan. The Red Plan must be available in German and in English.

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Page 9-1

9. REFERENCES

Federal Recycling Act (Kreislaufwirtschaftsgesetz – KrWG). 24 February 2012, last amended 9 Oct 2020

Ordinance on the European Waste Catalogue (Abfallverzeichnisverordnung AVV). 10 December 2001, last amended 30 Jun 2020

Ordinance on facilities handling water-endangering substances (Verordnung über Anlagen zum Umgang mit wassergefährdenden Stoffen – AwSV), 18 April 2017, last amended 19 Jul 2020

Environmental Final Governing Standards for Germany, US Army IMCOM Europe Region, September 2020

HQ USAREUR & IMCOM Europe, 8 May 2012, Army in Europe Regulation AER 200-1, Environmental Quality, Army in Europe Environmental Quality Program.

Army Regulation AR 200-1, Environmental Protection and Enhancement. HQ Department of the Army, Washington DC, 13 December 2007

ADR 2023, European Agreement concerning the International Carriage of Dangerous Goods by Road, 27. Änderungsverordnung 1 January 2023

Appendix 1 List and locations of HWSA, HWAPs, HWBATs, HWCONs, and

Waste Oil Tanks

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Appendix 1-1

Table A-1.1.1 List of HWAPs

ARLOC

Facility Number

Unit/ Activity/ Organization Official Waste Generator

Number

GE72T 116 DPW/ED H01400101-3

GE46J 979 MWR Golf Course H05400174-6

GE656 2316 DPW/ ED H01400101-3

GE656 2353 Garrison Maintenance Contractor H01400101-3

GE656 2349 AAFES Gas Station H01400101-3

GE643 2929 MWR Auto Skills Center H02400100-2

GE643 2935A AAFES CCC H02400100-2

GE643 2935B TLSCE/ MAV Det. H02400100-2

GE643 2958A 554th Military Police H02400100-2

GE643 2958B 405th AFSB LRC H02400100-2

GE643 2969 1/10th Special Forces Group H02400100-2

GE643 2970 NSWU/2 H02400100-2

GE643 2974 DPW/ ED H02400100-2

GE643 2996A Dental Clinic H02400100-2

GE643 2996B Veterinary Clinic H02400100-2

GE19B 3219 DPW/ ED H03190580-9

GE44F 3318 DPW Shops H01400101-3

GE44F 3319 MWR Arts and Crafts Shop H01400101-3

GE44F 3320A 405th AFSB BASOPS H01400101-3

GE44F 3320B MWR Auto Skills Center H01400101-3

GE44F 3324 AMC/AAFES Gas Station H01400101-3

GE44F 3360 DPW Recycling Yard H01400101-3

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Appendix 1-2

Table A-1.1.2 List of HWBATs

ARLOC Facility Number Unit/ Activity/ Organization Official Waste Generator Number

GE72T 146 RB Commissary/AAFES Furniture Store H01400101-3

GE72T 148 RB Elementary/Middle Schools H01400101-3

GE72T 151 RB Fitness Center H01400101-3

GE656 2211 Health Clinic H01400101-3

GE656 2325 Patch Post Office H01400101-3

GE656 2333 Garrison Maintenance Contractor H01400101-3

GE656 2337 Patch Fitness Center H01400101-3

GE656 2349 AAFES Gas Station H01400101-3

GE656 2350 Patch Commissary H01400101-3

GE656 2388 Patch Middle School H01400101-3

GE656 2390 Patch Elementary School H01400101-3

GE643 2903 Panzer Main Exchange, PX H02400100-2

GE643 2918 Patch Elementary School H02400100-2

GE643 2952 Military Clothing H02400100-2

GE643 2957 Panzer Commissary H02400100-2

GE643 3080 Panzer High School H02400100-2

GE643 3081 Panzer Elementary School H02400100-2

GE643 2990 Panzer Fitness Center H02400100-2

GE19B 3220 VMR SPMAGTF C12W, Hangar 2 H03190580-9

GE19B 3227 Hangar 5 Outside H03190580-9

GE19B 3254 DES Fire Department H03190580-9

GE19B 3255 Airfield Management H03190580-9

GE44F 3312 Kelley Post Office H01400101-3

GE44F 3317 Bus station H01400101-3

GE44F 3324 AMC/AAFES Gas Station H01400101-3

GE44F 3326 Kelley Fitness Center H01400101-3

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Appendix 1-3

Table A-1.1.3 List of HWCONs

ARLOC Facility Number Unit/ Activity/ Organization Official Waste Generator

Number

GE46J 975 MWR Golf Course DPW is not responsible

GE656 2330 Food Court DPW is not responsible

GE643 2903 PX DPW is not responsible

GE643 2913 German Kantine DPW is not responsible

GE643 2998 Bowling Center DPW is not responsible

GE44F 3362 Subway DPW is not responsible

Table A-1.2 List of HWSA

ARLOC

Facility Number

Unit/ Activity/ Organization Official Waste

Generator Number AwSV Hazard

Level

GE44F 3371 DPW/ ED H01400101-3 D

Table A-1.3 List of Waste Oil Tanks

ARLOC

Facility Number

Unit/ Activity/ Organization Official Waste

Generator Number AwSV Hazard

Level

GE46J 979 MWR Golf Course H06500174-6 B

GE643 2929 MWR Auto Skills Center H02400100-2 C

GE643 2930 MWR Auto Skills Center H02400100-2 N/A*

GE643 2935A TLSCE/ MAV Det./ AAFES H02400100-2 C

GE643 2958A 55th Military Police H02400100-2 C

GE643 2969 1/10th Special Forces Group H02400100-2 C

GE643 2970 NSWU/ 2 H02400100-2 B

GE19B 3262 VMR SPMAGTF C12W H03190580-9 C

GE44F 3320 405th AFSB BASOPS & MWR Auto Skills Center H01400101-3 C

GE44F 3371 DPW/ED H01400101-3 B

*Tank not in use

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Appendix 1-4

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Appendix 1-4

Figure 1: Locations of HWAPs, HWBATs, HWCONs, and Waste Oil Tanks at Patch Barracks

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Appendix 1-5

Figure 2: Locations of HWAPs and HWBATs at Robinson Barracks

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Appendix 1-6

Figure 3: Locations of HWAPs, HWCONs, and Waste Oil Tanks at Kornwestheim Golf Course

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Appendix 1-7

Figure 4: Locations of HWSA, HWAPs, HWBATs, HWCONs, and Waste Oil Tanks at Kelley Barracks

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Appendix 1-8

Figure 5: Locations of HWAPs, HWBATs, and Waste Oil Tanks at Echterdingen Airfield (East)

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Appendix 1-9

Figure 6: Locations of HWAPs, HWBATs, HWCONs, and Waste Oil Tanks at Panzer Kaserne

Appendix 2 Sample Container Label

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Appendix 2-1

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Appendix 2-2

Appendix 3 State-Specific Requirements

Update – USAG Stuttgart Hazardous Waste Management Plan – February 2024 Appendix 3-1

STATE-SPECIFIC STORAGE TANK REQUIREMENTS (according to German regulation for handling of substances that are hazardous to water – AwSV)

The following text provides short excerpts of the most relevant paragraphs of the AwSV. For further details, please refer to the original document.

§39 Hazard levels of facilities

(1) Operators must assign a hazard level to facilities according to the table below. In the case of liquid substances, the decisive volume for the facility in question should be taken as the basis, while the decisive mass for the facility in question should be taken as the basis in the case of gaseous and solid substances.

Table A-3.1 Hazards levels based on volume and Water Hazard Class

Determination of the hazard levels Water hazard class (WHC) Volumes in cubic metres (m3) or mass in tonnes (t) 1 2 3

≤ 0.22 m3 or 0.2 t Level A Level A Level A

> 0.22 m3 or 0.2 t ≤ 1 Level A Level A Level B

> 1 ≤ 10 Level A Level B Level C

> 10 ≤ 100 Level A Level C Level D

> 100 ≤ 1 000 Level B Level D Level D

> 1 000 Level C Level D Level D

More details to this table are described in sections (2) to (11) of §39 AwSV.

§43 Documentation relating to the facility

(1) The operator shall keep documentation relating to the facility, which includes the key information pertaining to it. This includes, in particular, information on the layout and demarcation of the facility, on the substances used, the design, the materials used in the individual parts of the facility, on safety devices and safeguards, fire water retention and stability.