tinkerafb_HWMP.pdf

U. S. AIR FORCE HAZARDOUS WASTE MANAGEMENT PLAN

Tinker Air Force Base

4/2/2017

About This Plan This installation-specific Environmental Management Plan (EMP) is based on the U.S. Air Force’s (AF) standardized Hazardous Waste Management Plan (HWMP) template. This plan is not an exhaustive inventory of all hazardous waste (HW) requirements and practices. Where applicable, external resources, including Air Force Instructions (AFIs); AF Playbooks; federal, state, local and Final Governing Standards (FGS); and permit requirements, as applicable, are referenced.

Each section of this HWMP plan begins with standardized, AF-wide “common text” language that addresses AF and Department of Defense (DoD) policy and federal requirements. This common text language is restricted from editing to ensure that it remains standard throughout all plans. The common text language is maintained and updated by the designated Office of Primary Responsibility (OPR) with assistance from the Office of Collateral Responsibility (OCR), as appropriate. Immediately following the AF-wide common text sections, are Installation sections. The Installation sections contain installation-specific content to address state, local and installation-specific requirements. Installation sections are unrestricted and are maintained and updated by AF environmental Installation Support Teams (ISTs) and/or installation personnel.

This document is optimized to be accessed and viewed electronically. The eDASH website at https://cs1.eis.af.mil/sites/edash/ is the primary communication tool for AF EMPs.

https://cs1.eis.af.mil/sites/edash/

TABLE OF CONTENTS

DOCUMENT CONTROL

1.0 OVERVIEW AND SCOPE

2.0 INSTALLATION PROFILE

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

4.0 GENERAL ROLES AND RESPONSIBILITIES

5.0 TRAINING

6.0 RECORDKEEPING AND REPORTING

7.0 PROCEDURES

7.1 Waste Inventory

7.2 Waste Identification

7.3 Container Management

7.4. Labeling and Marking

7.5 Accumulation Area Management

7.6 Transportation

7.7 Turn In/Disposal

7.8 Inspection

7.9 Waste Minimization

7.10 Preparedness and Prevention

7.11 Waste Specific Procedures

8.0 REFERENCES

9.0 ACRONYMS

10.0 DEFINITIONS

11.0 INSTALLATION-SPECIFIC CONTENT

APPENDICES

Appendix A – Waste Analysis Plan

Appendix B – Emergency Contacts Tinker AFB

Appendix C: Example Forms and Signage

DOCUMENT CONTROL

Record of Updates – The HWMP is updated as changes to waste generation and management practices occur, including those driven by changes in applicable regulations.

Record of Updates

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

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Record of Annual Review – In accordance with (IAW) AFI 32-7042, Waste Management, this plan is reviewed annually, updated as appropriate, and approved by the Environmental Safety and Occupational Health Council (ESOHC). Formatting and administrative changes do not require ESOHC review.

Record of ESOHC Annual Review

Review Date Review Participants Notes/Remarks Result in Plan Update? (Yes or No)

3/8/2018 Kyle Barton No changes were made No 3/8/2019 Kyle Barton Minor changes made to

Appendix A.

No

3/27/2020 Kyle Barton No changes were made No

1.0 OVERVIEW AND SCOPE

This HWMP contains procedures for management of HW. In lieu of federal, state or FGS requirements, AFI 32-7042, Waste Management, acts as the main driver for the HWMP. The HW Playbook serves as supplemental guidance to this plan.

Installation Supplement – Overview and Scope

This instruction applies to all generators of hazardous and non-hazardous industrial wastes on Tinker AFB, including wastes generated by both government and contractors. Non-hazardous industrial wastes will be managed in the same manner as hazardous wastes.

2.0 INSTALLATION PROFILE

Installation Profile

Scope of Plan Tinker AFB’s Hazardous Waste Management Plan (HWMP) covers all organizations that generate hazardous and non-hazardous industrial wastes, establishes waste management procedures, and outlines organizational responsibilities.

Tinker AFB is home to eight major DoD, Air Force and Navy tenants with critical national defense missions, including:

• The Oklahoma City Air Logistics Complex (OC- ALC) is the largest organization on Tinker AFB with more than 9,400 military and civilian employees. It is the largest of three depot repair complexes in the Air Force Materiel Command. It provides depot maintenance on the C/KC-135, B- 1B, B-52 and E-3 aircraft, expanded phase maintenance on the Navy E-6 aircraft, and maintenance, repair and overhaul of F100, F101, F108, F110, F118, F119 and TF33 engines for the Air Force, Air Force Reserve, Air National Guard, Navy and foreign military sales.

• The 552d Air Control Wing, which is part of the AF’s Air Combat Command mobile strike force, is responsible for operations, maintenance, logistics, training, and combat support of E-3 airborne warning and control system (AWACS) aircraft, whose radar and other sensors provide deep-look surveillance, warning, interception control and airborne battle management.

• The Navy’s Strategic Communications Wing ONE provides a communications link to the submerged fleet of ballistic missile submarines. OC-ALC airframe artisans perform depot work on the Navy’s E-6 Mercury airplanes and sailors perform field level work.

• The 507th Air Refueling Wing, an Air Force Reserve flying unit, has the primary mission of supporting U.S. Military and NATO aircraft with aerial refueling missions worldwide.

• The 38th Cyberspace Engineering Installation Group, which has responsibility for engineering and installation of all communications and electronic facilities for the Air Force worldwide.

• The Defense Logistics Agency (DLA) Distribution Oklahoma City, provides the receipt, storage, issue, inspection, and shipment of material, including material quality control, preservation and packaging, inventory, transportation functions, and pickup and delivery services in support of the OC- ALC and other Tinker-based organizations.

• The Defense Enterprise Computing Center Oklahoma City, which is the local branch of the Defense Information Systems Agency (DISA) that operates computer systems for the base and serves over 100 other bases worldwide.

• The Missile Sustainment Division reports to the AF Nuclear Weapons Center (AFNWC). The division manages the program for the long range stand-off cruise missiles and the bomber weapons integration equipment.

72 ABW provides critical base functions and support services to headquarters, AF Sustainment Center, the OC- ALC, and all other associated units. Organizations assigned to 72 ABW include:

• 72d Medical Group (72 MDG)

• 72d Mission Support Group (72 MSG)

• 72d Operations Support Squadron (72 OSS)

• 72d Civil Engineer Directorate (72 ABW/CE)

• 72d Logistics Readiness Squadron (72 LRS)

• 72d Force Support Squadron (72 FSS)

• 72d Communications Directorate (72 ABW/SC)

• 72d ABW Plans and Programs Office (72

ABW/XP)

• 72d ABW Equal Opportunity/Alternate Dispute

Resolution (72 ABW/EO/ADR)

• 72d ABW Public Affairs (72 ABW/PA)

• 72d ABW Comptroller Squadron (72 CPTS)

• 72d ABW Staff Judge Advocate (72 ABW/JA)

• 72d ABW Safety Office (72 ABW/SE)

• Chapel Division (72 ABW/HC)

• 72d Security Forces Squadron (72 SFS)

Office of Primary Responsibility

(OPR)

72 ABW/CEIEC has overall responsibility for implementing the HW management program and is the lead organization for monitoring compliance with applicable federal, state and local regulations

HW Program Manager Mr. Kyle Barton Alternate HW Program Manager Mr. Kim Kline Emergency contacts Refer to Appendix B to this HWMP Waste registration numbers OK1571724391 HW generator status Large Quantity Generator Universal waste handler status Large Quantity Handler of Universal Waste Permitted HW operations One Permitted Storage Facility – Up to 1-year Federal or FGS regulatory references 40 CFR 260 through 279 State and local regulatory agencies Oklahoma Department of Environmental Quality (ODEQ) State and local regulatory references Title 252, Oklahoma Administrative Code, Chapter 205:

“Hazardous Waste Management.”

Approved HW disposal contractors Contract through Defense Logistics Agency Disposition

Services (DLA-DS).

HW accumulation sites Refer to EESOH-MIS for Complete List.

HW accumulation time limits 90 Calendar Days HW generator reporting frequency Monthly, Quarterly, and Biennial

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

The AF environmental program adheres to the Environmental Management System (EMS) framework and its Plan, Do, Check, Act cycle for ensuring mission success. Executive Order (EO) 13693, Planning for Federal Sustainability in the Next Decade, U.S. Department of Defense Instruction (DoDI) 4715.17, Environmental Management Systems, AFI 32-7001, Environmental Management, and international standard, ISO 14001:2004, provide guidance on how environmental programs should be established, implemented, and maintained to operate under the EMS framework.

The HW management program employs EMS-based processes to achieve compliance with all legal obligations and current policy drivers, effectively managing associated risks, and installing a culture of continuous improvement. The HWMP serves as an administrative operational control that defines compliance-related activities and processes.

4.0 GENERAL ROLES AND RESPONSIBILITIES

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

• Wing/Installation Commander

• ESOHC

• HW Manager/Alternate

• Shop/HW Generator Personnel

• Initial Accumulation Point (IAP) and Hazardous Waste Accumulation Site (HWAS)

Supervisors/Managers

• Unit Commanders

• Unit Environmental Coordinators (UECs), see AFI 32-7001 for role description

• Contracting Officer

• Defense Logistics Agency Disposition Services

• Tenant Organizations

• AFCEC

Detailed information about typical responsibilities for these and other roles is available in the HW Playbook. Additional HW management-related roles and responsibilities are described throughout this plan and in referenced documents.

Installation Supplement – General Roles and Responsibilities

Organizational Responsibilities:

Although the 72 ABW/CEIEC is responsible for overall management of the hazardous waste program at Tinker, all base personnel are responsible for compliance. The 72 ABW Commander is ultimately responsible for ensuring compliance with laws governing HW management and proper disposal from all activities on base. Management and disposal of HW by DLA-DS or by contractors does not relieve the installation commander of this responsibility, including proper final disposal and accuracy of the HW manifest. Each generating organization is responsible for conducting proper management and pre-disposal practices when managing its hazardous waste. In addition to that basic responsibility, the following responsibilities are designed to ensure a smooth flow in the hazardous waste management system at Tinker AFB. In the event of regulatory modifications and/or amendments, each generating organization, as advised by 72 ABW/CEIEC, will be responsible for ensuring their actions complies with Federal, State and Air Force requirements. Training requirements, as mandated by AFMAN 32-7002, Environmental Compliance And Pollution Prevention, 4 Februarty 2020, states, “All personnel, whose work involves HW and their immediate supervisors, must receive and successfully complete HW training appropriate to their job responsibilities.”

Installation Commander will:

• Ensure that a HW Management Plan (HWMP) is current, available, and followed by installation personnel. Ensure that appropriate HW management practices are emphasized to all installation personnel through education and training, to include shop level training, as needed.

• Sign all installation HW permit applications or other regulatory binding agreements as required;

this authority cannot be delegated.

• Sign, or delegate in writing the authority to sign, HW manifests. Installation Commanders shall ensure signature delegation remains with a qualified (trained) DoD employees (civilian, military, guard, reserve, or host nation), or appropriately assigned State employees in the case of the ANG.

The person delegated to sign manifests must be physically present during transfer or shipment of waste off-site. For installations where the HW management function is outsourced or there is not a qualified DoD employee, the Installation Commander will send a waiver request to AFCEC/CZ.

IAW Sec 2.4.2, NGB/A4 and AFRC/A4 will approve for ANG and AFRC bases respectively in concert with AFEC/CZ.

• Ensure the proper disposal of all wastes from the installation.

• Ensure that employees handling HW have HW responsibilities reflected in their job descriptions.

• Ensure appropriate use of the standardized Air Force HW system, Enterprise, Environmental Safety and Occupational Health – Management Information System (EESOH-MIS), to include tracking of waste generation from shop processes, transfer to central accumulation storage, cost, and turn-in for disposal.

Environmental Safety and Occupational Health Committee (ESOHC) will:

• Review and approve SW and HW policies and guidance, review installation industrial sold waste (ISW) and HW management plans and programs, monitor progress, and advise leadership (refer to AFI 90-801, Environment, Safety, and Occupational Health Councils for further guidance).

Civil Engineering Directorate, Environmental Compliance Section (72 ABW/CEIEC) will:

• Serve as the central base coordinator for the hazardous waste program and for questions regarding compliance with Federal, State, DoD and Air Force requirements.

• Set forth policies on all issues related to hazardous waste compliance regulations.

• Chair the Hazardous Waste Working Group (HWWG) and provide space for meetings.

• Maintain EESOH-MIS to include the following: type, quantity, location, process of generation, disposal cost, disposal method and disposal location.

• Represent the base during compliance inspections by Federal, State and local regulatory officials, and respond to inspection related questions.

• Coordinate with the Staff Judge Advocate’s Office and respond to inquiries regarding policy or management decisions and interpretation of regulations.

• Advise UECs and 72 FSS/FSDEB on changes to hazardous waste regulations, manuals and other directives as appropriate.

• Review requests from UECs for new, or modifications to current, hazardous waste management sites and ensure appropriate changes are made in the hazardous waste tracking system (HWTS).

• Conduct periodic compliance monitoring visits to determine status of accumulation methods and management procedures.

• Develop, review and update as necessary, base instructions, manuals, contingency plans and other documents dealing with hazardous waste management. This will be performed annually or as significant laws or regulations are passed.

• Monitor and modify as necessary the Resource Conservation and Recovery Act (RCRA) operating permits for Tinker AFB.

• Coordinate with DLA-DS and 72 ABW/JA concerning modifications to permits.

• Ensure proper closure of hazardous waste management sites.

• Coordinate with ODEQ to update and maintain a current Oklahoma State Disposal Plan for Tinker AFB.

• Prepare and transmit reports concerning the generation, shipment and disposal of hazardous wastes. These include the Biennial Report (40 CFR 262.41), Exception Reports (40 CFR 262.42) and monthly and quarterly reports to ODEQ.

• Participate in the 3-year Course Review of the Hazardous Waste Training Course provided by 72 FSS/FSDEB and provide information to ensure its accuracy.

• Oversee operation of the Permitted Storage Facility (PSF), Hazardous Waste Management Facility (HWMF) and the Empty Container Processing Facility (ECPF).

• Provide guidance to those not using the HWMF on pre-disposal processing of hazardous waste property.

• Coordinate with DLA-DS and its disposal contractor to ensure smooth flow of hazardous waste from PSF to ultimate disposal or recycling facilities.

• Assist DLA-DS on disposal contract modifications, claims or disputes.

• Assist Air Force Civil Engineering Center (AFCEC) in developing and modifying the installation hazardous waste management contract, and help resolve any claims or disputes.

• Coordinate with on-base contractors for all shipments of hazardous waste leaving the installation.

• Perform an annual review of waste profiles generated at Tinker AFB.

• Develop and maintain a current file of hazardous waste profile sheets in conjunction with DLA-

DS.

• Ensure hazardous waste manifests, for generators not required to use DLA-DS, are properly completed and signed by authorized persons.

• Update “Signature Authority for Uniform Hazardous Waste Manifests” letter authorizing persons to prepare and sign TAFB Manifests and Land Disposal Restriction (LDR) forms.

• Maintain files of manifests and LDR forms from all Tinker AFB generators.

• Ensure a copy of each manifest, with the handwritten signature of the disposal facility owner or operator, is received within 45 days of shipment.

• Maintain files of Certificates of Disposal permanently and the disposal contractor’s delivery orders for at least three years.

• Maintain a record of waste disposal cost information within the HWTS.

• Review the 19-2, Oil and Hazardous Substances Integrated Contingency Plan, and revise as necessary.

• Attend formal instruction to meet RCRA and DOT requirements IAW AFMAN 32-7002.

• Coordinate any changes to funding requirements for disposal of hazardous and non-hazardous industrial wastes with AFCEC.

72 ABW/CEIEA- Environmental Laboratory will:

• Maintain a credible chemical laboratory capable of producing accurate chemical analysis by methods specified in 40 CFR 261.

• Prepare appropriate reports for analyses requested by 72 ABW/CEIEC.

• Contact 72 ABW/CEIEC with any discrepancies found between samples and sample description.

• Review the Waste Analysis Plan (WAP) annually and update as necessary.

Air Force Civil Engineering Center (AFCEC) will:

• Manage corrective action and remediation projects at Solid Waste Management Units (SWMUs) and National Priorities List (NPL) sites at Tinker AFB.

• Ensure that manifests for shipment of hazardous waste from SWMUs and NPL sites are coordinated through 72 ABW/CEIEC.

• Ensure adequate funding for disposal of hazardous and non-hazardous industrial wastes are programmed.

Units that Generate Any Hazardous Waste will:

• Designate a primary and alternate Hazardous Waste POC for each waste site. The organizations may either designate the POCs in writing, or designate them within EESOH-MIS. This designation shall be made within 5 working days of appointment.

• Ensure that the designated monitors of hazardous waste and their supervisors receive annual RCRA training as required by 40 CFR, such as the initial and annual hazardous waste training courses provided by 72 FSS/FSDEB.

• Supervisors will examine employee training to ensure that adequate site- and task specific familiarization is accomplished, and supplement with on-the-job training, as needed.

• Supervisors will contact the organization’s training manager to request training. The training manager will then contact 72 FSS/FSDEB to schedule personnel for training.

• Ensure that supervisors maintain training records for personnel involved in hazardous waste management. The records may be kept in hard copy or electronic format.

• Ensure no accumulation of hazardous waste occurs except at appropriately established management sites.

• For proper characterization of waste streams, provide essential information to the organization’s UEC when processes or chemicals change, or if new waste streams are identified.

• Package, mark and label all containers of hazardous waste as instructed herein during accumulation and prior to turn-in to DLA-DS if containers are not processed through the HWMF.

• Take active measures to reduce the volume of hazardous waste generated.

• Coordinate with the Hazardous Materials Management Program (HMMP) to ensure surplus hazardous materials are made available to all potential users.

• Operate and maintain hazardous waste management sites as instructed herein.

• Coordinate with the HWMF for receipt of bar-coded hazardous waste containers and for their return when full.

• Perform Initial Response actions outlined in Section 7.10 of this HWMP upon spilling a hazardous substance or waste. Organization shall clean up all spills that are within the organization’s internal capabilities. All others spills shall require activation of the TAFB Plan 19-2, Oil and Hazardous Substances Integrated Contingency Plan. emergency response procedures.

• Ensure that statements of work (SOW) for projects that involve generation of hazardous waste are routed to their organization’s UEC, who will coordinate with 72 ABW/CEIEC as necessary and to set up Initial Accumulation Points (IAPs). SOWs must include training requirements for all involved personnel. Contracting Officer Representatives (CORs) shall insure that requirements of this instruction are included in the contract and brought to the contractor's attention. CORs may be appointed as IAP managers for their contractors. MILCON projects will provide funding for the disposal of industrial and hazardous wastes and may require contractors to provide those services. If the SOW requires 72 FSS/FSDEB training, a copy of the SOW must be provided to 72 FSS/FSDEB for review prior to entering into the contract.

• Supervisors at hazardous waste management sites shall sign accumulation inspection forms and inventory logs, keep the original copy of these forms and logs for a period of one year and send copies to their UEC. Digital copies are sufficient to meet this requirement.

• When a site is no longer needed, ensure that all hazardous waste management sites comply with the guidelines in this instruction for hazardous waste facility closure.

• Maintain list of hazardous waste streams currently generated within the unit. The listing generated in EESOH-MIS is adequate for this requirement and should be used.

• For IAP Manager Inspection responsibilities, see section 7.8 of this plan.

• Conduct self-assessments (as a part of Stage One audit assessment requirements), maintain self-assessment records, and comply with 40 Code of Federal Regulations (CFR 262 Subpart C), Generator Requirements.

• Implement corrective actions.

• Ensure funding is available for HW container/IAP supplies and equipment.

Unit Environmental Coordinators (UECs) will:

• Serve as the coordinator in their organization for disseminating information and providing guidance on proper accumulation and management of hazardous wastes.

• Provide current information to the organization commander, and unit supervisors about hazardous waste issues.

• Coordinate with 72 ABW/CEIEC on meeting needs of the organization’s hazardous waste management program and on correcting any deficiencies that may be discovered.

• Represent their organization at all HWWG meetings.

• Ensure that Emergency Response Plan is current and posted at accumulation sites.

• Maintain a current list of waste sites within their organization and coordinate with 72 ABW/CEIEC for approval to establish new sites or change existing waste sites. EESOH-MIS shall be used to maintain this listing.

• Ensure that primary and alternate waste site POCs are current in EESOH-MIS for all waste sites in their organization.

• Coordinate with organizational training manager about number of personnel needing annual Hazardous Waste Training from 72 FSS/FSDEB.

• Ensure original inspection forms and waste inventory logs for initial accumulation points and accumulation sites are maintained at the generation site for at least one year. The copies should be received each month by the UEC.

• The UEC will review the copies of the forms for problem trends and maintain them in an orderly manner for three years for inspection purposes. Electronic versions of these forms are acceptable.

• Conduct an inspection of all hazardous waste management sites within their organization every month, documenting and reporting findings to 72 ABW/CEIEC. For larger organizations, this may be delegated to a Hazardous Waste Monitor within the organization. The required weekly inspections documented on TINKER AFB Form 487, Initial Accumulation Point Management Aid, may be used by the Hazardous Waste Monitor as documentation for monthly inspections. If delegated, the UEC will still inspect each site at least semi-annually.

• Serve as the organization’s point of contact for all environmental inspections.

• Conduct periodic (annually at a minimum) review of their organization’s waste stream inventory.

Submit information to 72 ABW/CEIEC upon discovery of new or modified waste streams.

• Oversee coordination with HMMP if unauthorized chemicals appear in waste streams.

• Review their organization’s SOWs for projects that involve generation of hazardous waste.

Coordinate with 72 ABW/CEIEC for any hazardous waste requirements.

• Attend formal instruction that acquaints the student with the details of RCRA regulations in 40 CFR 260 through 279; applicable State Laws and regulations; DoD, Air Force and local requirements; and in annual refresher classes, updates the student on changes to those rules. This training can be obtained through credible training institutions or companies approved by CEIEC or through AF Training Organizations.

Fire Protection Division (72 ABW/CEF) will:

• Provide technical assistance and advice concerning necessary fire protection for hazardous waste management sites.

• Provide a subject matter expert when requested for initial and annual hazardous waste training.

• Inspect hazardous waste management sites on a periodic basis to ensure compliance with USAF and National Fire Protection Association standards.

• Coordinate on establishment of hazardous waste management sites.

Safety Offices (72 ABW/SE, OC-ALC/SE, and 552 ACW/SE) will:

• Provide technical assistance and advice concerning proper handling and storage procedures at hazardous waste management sites.

• Provide a subject matter expert when requested to discuss safety issues at initial and annual hazardous waste training.

• Inspect hazardous waste management sites on a periodic basis to ensure compliance with USAF and OSHA directives.

• Coordinate on establishment of hazardous waste management sites.

• Provide a representative to HWWG.

Staff Judge Advocate (72 ABW/JA) will:

• Advise CEIEC of proper legal interpretation of hazardous waste laws and regulations and any changes in applicable legal requirements.

• Coordinate on reports, permits, permit fees and inquiries submitted to the ODEQ or EPA concerning hazardous waste management issues.

• Review all proposed contracts relating to hazardous waste management, particularly statements of work and specifications, in the earliest stages of procurement possible.

• Provide representative to HWWG.

• Review modifications to this instruction and other documents pertaining to hazardous waste management.

• Provide legal guidance on all enforcement actions arising out of hazardous waste management activities, including responses to notices of violations, negotiation with regulatory authorities on compliance agreements and defense of Tinker AFB in litigation. Coordinate with higher headquarters and the Department of Justice (DOJ) as required.

Classification Section (72 FSS/FSC) will:

• Upon request from supervisors of areas that produce hazardous waste, advise them of conditions that could make it necessary to describe hazardous waste managers’ and operators’ duties in their job descriptions.

• If applicable, ensure supervisors properly describe duties in job descriptions and that necessary administrative actions are taken to properly update job descriptions.

Bioenvironmental Engineering Services (72 AMDS/SGPB) will:

• Provide technical assistance and advice concerning personnel protective equipment and safe handling procedures at hazardous waste management sites.

• Provide a subject matter expert when requested to discuss chemical hazard issues at initial and annual hazardous waste training.

• Provide advice on industrial hygiene to all work areas for employee health.

• Coordinate on establishment of hazardous waste management sites.

• Provide representative to the HWWG.

• Provide assistance in disposal of mixed waste.

Occupational Medicine (72 MDG/SGPO) will:

• Ensure employees involved in the handling of hazardous waste receive appropriate occupational health physical examinations.

Industrial Training Branch (72 FSS/FSDEB) will:

• Provide initial and annual training classes for all personnel involved in hazardous waste management and their direct supervisors, enabling them to perform their duties in a manner that meets Federal, State, DoD, Air Force, local statutes, regulations and requirements. EPA requirements are outlined in 40 CFR 264.16 for permitted management sites and 40 CFR 265.16 for non-permitted management sites. Hazardous waste generators are included by reference at 40 CFR 262.34(a)(4). The following elements of training are required:

o Introduction to the RCRA.

o Identification of hazardous waste.

o Accumulation point management.

o Container use, marking and labeling and on-base transportation.

o Waste turn-in procedures.

o Manifesting and off-base transportation of hazardous waste.

o Spill prevention and emergency response.

o Waste reduction.

o Personnel safety and health and fire safety.

• Provide instructors who have attended formal instruction that in the initial phase acquaints the student with the details of the RCRA regulations in 40 CFR 260 through 279; applicable State Laws and regulations; DoD, Air Force and local requirements and in annual refresher classes, updates the student on changes to those rules. Instructor’s training must give priority to using HAF-approved HW education/ training sources such as AFIT Civil Engineer School HW Course WENV 521 and WESS 010 HW Accumulation Satellite seminar, and the Air Force HW web-based training available from AFCEC.

• Review SOW involving FSDT training of contractors.

Defense Logistics Agency Services (DLA-DS) will:

• Advise 72 ABW/CEIEC about how and when segregation of waste streams would increase the probability of recycling the waste.

• Advise 72 ABW/CEIEC when a market is available for reutilizing hazardous materials and wastes that are being generated.

• Verify the suitability of Permitted Treatment, Storage and Disposal Facilities (TSDFs) for all waste shipped through DLA-DS.

• Advise 72 ABW/CEIEC of any changes in defense turn-in document procedures or in packing, marking and labeling requirements.

• Provide a subject matter expert, when requested, for initial and annual hazardous waste training to explain role of DLA-DS and turn-in requirements.

• Complete EPA Form 8700-22, Uniform Hazardous Waste Manifest for all shipments of Tinker AFB hazardous wastes that are shipped off-site through the DLA-DS disposal contract and transmit a copy to 72 ABW/CEIEC within two hours after acceptance by the transporter. If transporter acceptance takes place after duty hours the manifest will be delivered to the Fire Department, if possible, or held until the next duty day and delivered to 72 ABW/CEIEC.

• Request delegation of authority from 72 ABW/CE for personnel who will prepare and sign Hazardous Waste Manifests and Land Disposal Restriction forms. Proof of training will be required to receive that delegation.

• Package, mark, label and offer placards (if these actions have not already been taken) for shipments of hazardous waste from Tinker AFB through the DLA-DS disposal contract according to applicable DOT hazardous materials regulations and DLA-DS requirements.

• Ensure input from Tinker AFB operations by coordinating with 72 ABW/CEIEC and 72 ABW/JA during negotiations for hazardous waste disposal contracts.

• Ensure that Certificates of Disposal are deliverable items in disposal contracts.

• Confirm that each hazardous waste shipment reached the disposal site safely and the disposal site received the shipment described on the manifest.

• Activate the site-specific contingency plan upon spilling a hazardous substance or during any other applicable emergencies.

• Attend initial and annual HW training, or equivalent, which enables them to perform their duties in a manner that meets Federal, State, DoD, Air Force and local laws, regulations and requirements. EPA requirements are outlined in 40 CFR 264.16 for permitted management sites.

• Appoint a Primary and Alternate UEC.

• Maintain a current copy of the RCRA Part B Operating Permit for Tinker AFB, a copy of Tinker AFB Plan 19-2, Oil and Hazardous Substance Integrated Contingency Plan and a copy of this instruction.

5.0 TRAINING

HW awareness training is provided to satisfy regulatory requirements and needs. All personnel whose work involves HW, and their immediate supervisors, must successfully complete HW training appropriate to their job responsibilities. Until the employee has received the appropriate HW training, the employee may only handle HW under the supervision of a trained individual. HW training is provided by authorized personnel. Training records are maintained IAW the Recordkeeping and Reporting section of this plan.

Installation Supplement – Training

Personnel involved in hazardous waste management must complete a program of instruction that enables them to perform their duties in a manner that meets Federal, State, DoD, Air Force and local laws, regulations and requirements. EPA requirements are outlined in 40 CFR 264.16 for permitted management sites and 40 CFR 265.16 for non-permitted management sites. Hazardous waste generators are included by reference at 40 CFR 262.34(a)(4).

All personnel, whose work involves HW and their immediate supervisors, must receive and successfully complete HW training relevant to their job responsibilities. Training will occur within six months of an employee’s arrival or assignment to HW-related duties. Until the employee has received the appropriate HW training, the employee may only handle HW under the supervision of a HW trained individual.

Supervisors and personnel must also successfully complete annual refresher training. Those working at TSDFs and cleanup sites also need to adhere to Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) requirements.

The following elements of training are considered essential:

• Introduction to the RCRA.

• Identification of hazardous waste.

• Accumulation point management.

• Container use, marking, labeling and on-base transportation.

• Waste turn-in procedures.

• Manifesting and off-base transportation of hazardous waste.

• Spill prevention and emergency response.

• Waste reduction.

• Personnel safety and health and fire safety.

Installations must give priority to using HAF-approved HW education/ training sources such as AFIT Civil Engineer School HW Course WENV 521 and WESS 010 HW Accumulation Satellite seminar, and the Air Force HW web-based training available from AFCEC. Personnel may contact 72 ABW/CEIEC for other potential sources for the necessary training.

6.0 RECORDKEEPING AND REPORTING

Recordkeeping

The installation complies with the following U.S. Federal HW recordkeeping requirements.

Summary of HW Recordkeeping Requirements

Record* Retention Time** Citation HW determination documentation

3 years from the date that the waste was last sent to a TSDF

40 CFR 262.40

HW Biennial/Annual Report 3 years from the due date of the report 40 CFR 262.41 HW manifest 3 years from the day the waste was accepted by the initial transporter

40 CFR 262.40

HWAS inspection logs 3 years from the date the inspection was conducted

40 CFR 262.34

40 CFR 265.15 (d)

40 CFR 265.174

Exception reports 3 years from the due date of the report 40 CFR 262.42

Land restricted waste determination

3 years from date the determination was required to be conducted. If not required, 3 years from the date the waste was last sent to a TSDF

40 CFR 268.7

Land restriction notice and certification

3 years from the date the waste was last sent to a TSDF

40 CFR 268.7

Notification of intent to export waste

3 years from the date the HW was accepted by the initial transporter

40 CFR 262.53

EPA acknowledgement of consent (for exports)

3 years from the date the HW was accepted by the initial transporter

40 CFR 262.51

40 CFR 262.53

Waste export confirmation of delivery

3 years from the date the HW was accepted by the initial transporter

40 CFR 262.54

Annual report (required of primary exporters of HW)

3 years from the date the HW was accepted by the initial transporter

40 CFR 262.56

Employee training records (including appointment letters for key HW personnel)

Current personnel: until closure of the site;

Former personnel: 3 years from date the individual last worked there

40 CFR 262.34

40 CFR 264.16

40 CFR 265.16

*Permitted Treatment, Storage and Disposal Facilities (TSDF) comply with recordkeeping requirements established in their HW permit.

**Retention Time may be extended during the course of any unresolved enforcement action or as requested by the U.S. Environmental Protection Agency (EPA). The AF, through the Air Force Records Information Management System (AFRIMS), requires that HW-related reports, documents, studies, HW manifests, and disposal records (including contracts) are destroyed 50 years from the date of the record.

Reporting

The HW Manager, and other designated personnel, generate needed reports from EESOH-MIS.

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

Installation Supplement – Recordkeeping and Reporting

Record Keeping for Waste Sites (TAFB Form 487):

• During the first week of each month, the appropriate inspection form(s) from the previous month shall be sent to the UEC.

• The supervisor of the generating unit shall review and sign the forms before they are sent to the

UEC.

• Original copies of the forms shall be maintained by the generating unit for at least one year and be readily available for inspection.

• The UEC will review the forms for problem trends, maintain them in an orderly manner for three years and keep them on hand for inspection.

Personnel Records:

• Supervisors shall maintain job descriptions and training records for their employees. The supervisors shall maintain a tracking list of personnel who need training for their organization.

The supervisor shall coordinate with their training manager on training.

• Records should at a minimum include student’s name, job title, job description, previous HW training, dates of training, training provider and date of annual refresher course.

• Training records must be maintained as long as the individual is associated with, or for three years after the individual is no longer working with, hazardous waste. The records may be kept in hard copy or electronic format.

7.0 PROCEDURES

This section contains procedures for managing HW from identification, accumulation, offsite transportation and disposal. The HW Manager ensures that appropriate procedures are properly communicated and followed by all necessary personnel.

7.1 Waste Inventory

A current waste inventory can be generated within EESOH-MIS using the Ad-Hoc Reporting Tool or by completing the following steps:

• Log into EESOH-MIS; Select the “Reporting” option; Select “Hazardous Waste” to generate the Waste Site Waste Stream Summary Report

Installation Supplement – Waste Inventory

No additional requirements.

7.2 Waste Identification

The HW Manager determines the nature of waste based on a detailed qualitative analysis of the regulated waste generating process, associated Safety Data Sheet (SDS) information, and coordination with generating activity personnel involved in the use of hazardous materials. If uncertainties about a waste stream exist, the HW Manager pursues waste stream sampling and analysis IAW the Waste Analysis Plan

(WAP).

The WAP details the wastes that have been evaluated and analyzed, a description of the testing and analytical methods used, the HW sampling methods used, the location of samples taken for analysis and frequency, sample documentation, sample quality assurance and quality control procedures, and sample request procedures.

Generator knowledge and the results of the WAP are used to minimize waste re-characterizations to those instances where a process change has occurred or the waste stream is highly variable.

Installation Supplement – Waste Identification

WAP

The installation WAP is included in Appendix A to this HWMP.

Profile Sheets

For each waste stream identified that is disposed of through DLA-DS, an AF Form 1930, or equivalent format, will be completed and a copy given to DLA-DS. The AF Form 1930 may also be used for waste streams disposed of through contractors or a contractor prepared profile. A copy of all profile sheets will be reviewed for currency at least annually and updated as necessary. Update of profile sheets will be accomplished by 72 ABW/CEIEC with input from UECs as required.

7.3 Container Management

Container management procedures are as follows:

• Containers storing HW must be in good condition and meet permit, transportation and other applicable requirements. “Good condition” means there should be no severe rusting, no sharp-edged creases or dents, no bulging heads and no severe structural defects.

• Ensure that the waste material will not react with the container itself.

• Use plastic or plastic-lined steel drums to safely store corrosive wastes.

• Immediately transfer the contents of a leaking container to another container or over pack into a salvage drum.

• Containers with free liquid or drum contents on top must be cleaned or over packed in the case of a leak.

• Containers must remain closed at all times except when adding or removing waste. Adequate headspace must be maintained at all times when filling a container to account for content expansion.

Installation Supplement – Container Management

Container Management

• Whenever possible use serialized containers 55 gallons or less in capacity from the HWMF with HWTS generated labels.

• Container (or liner) must be compatible with the waste being contained.

• Container will be under control of the waste manager of the generating organization.

• Each container will be designated for waste generated by a specific process. No other wastes or materials will be placed in a designated container. Contents of container must agree with Profile Waste Stream for which the container was issued.

• Container must not be handled or moved from place-to-place in a manner that may cause them to rupture or leak.

• Never fill container holding liquids to more than 90 percent capacity (four inches from top for a 55-gallon drum).

• Never fill containers beyond manufactured weight capacity.

o Container capacities vary by size, material, and manufacturer. Contact HWMF at 734- 3285 for maximum weight, if maximum weight is a concern.

• A funnel may be left in a container bung if it is attached as an integral part of the container (such as with screw threads) and it has a lid that can be closed and latched.

• Container holding hazardous waste must be placed vertically and be separated from the floor by pallets, enviropacs, wheeled dollies or other means.

• All sealing mechanisms (locking rings, bung caps, bolts and nuts) will be installed and tightened prior to turn-in to the HWMF.

• Once the container is filled, the IAP manager must ensure that the Filled Date is marked on the container’s label with an indelible marker.

• The IAP Manager must ensure that the filled container is returned to the HWMF within three (3) calendar days of the filled date. Plan ahead for three-day weekends!

• Containers will be bonded when flammable liquids are transferred from one metal container to another metal container.

• If solids containing flammable liquids are to be placed in plastic bags or directly into plastic containers, then the plastic bags or plastic containers must be anti-static.

• Containers are still considered to be in “Good” condition as long as there are no major dents or creases, severe rusting, or damaged seals that threaten the structural integrity of the container.

Minor dents, scratches, surface rust, and touch-up paint may be present.

• At no time may containers be moved from one IAP to a separate IAP.

7.4. Labeling and Marking

Containers used for the accumulation and transportation of HW are properly labeled IAW applicable laws and regulations.

• Each container is properly marked and labeled from initial accumulation area to HWAS to disposal/turn-in. The waste-generating activity ensures that the label on each waste container is clearly visible for inspection. During accumulation at an IAP, HW containers are marked with the following:

o The words “Hazardous Waste” o A description of the contents of the container o The hazards associated with the waste

Once an IAP accumulates more than 55 gallons of HW (or 1 quart of acute HW), the IAP site manager marks the container with the date on which 55 gallons (or 1 quart of acute HW) is exceeded, and removes the excess of 55 gallons (or 1 quart of acute HW) within three days.

HW containers 110 gallons or less that are shipped offsite are marked with the following:

• “Hazardous Waste – Federal Law prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency”

• Generator’s name and address

• Generator’s EPA Identification Number

• Manifest tracking

These markings are:

• Durable

• In English, and/or appropriate host nation language

• Printed on or affixed to the surface of a package or on a label, tag or sign displayed on a background of sharply contrasting color

• Unobscured by labels or other attachments

• Located away from any other markings that might substantially reduce visibility or effectiveness

UW, or a container in which a UW is contained, is labeled and marked clearly with the date the material became a waste and the name of the waste, as described below:

• UW batteries must be labeled with any one of the following phrases: “Universal Waste- Battery(ies),” or “Waste Battery(ies),” or “Used Battery(ies)

• UW thermostats must be labeled with any of the following phrases: “Universal Waste-Mercury Thermostat(s),” “Waste Mercury Thermostat(s),” or “Used Mercury Thermostat(s)

• UW pesticides must be labeled with any of the following phrases: “Universal Waste-Pesticide(s)” or “Waste-Pesticide(s)

• UW lamps must be labeled with one of the following phrases: “Universal Waste—Lamp(s),” or “Waste Lamp(s),” or “Used Lamp(s)

Installation Supplement – Labeling and Marking

Ensure all containers obtained from the HWMF are correctly labeled. It is the responsibility of the requesting organization to ensure the container is correctly labeled. If a container is issued under one container but is needed for another waste stream, the using organization shall contact the HWMF for a new label. The using organization is responsible for coming to the HWMF to obtain the new label. If there are container compatibility issues between the waste streams, a new container will be issued.

7.5 Accumulation Area Management

Accumulation area management procedures are as follows:

1. IAPs are used to accumulate up to 55 gallons of HW or 1 quart of acute HW.

2. If HW or acute HW are accumulated in excess of these amounts, the generator marks the container with the date the amount was exceeded and transfers the container to a HWAS or TSDF within 3 days.

3. HW is accumulated in a HWAS for up to 90 days for a LQG, or 180 days (270 days if waste has to be shipped over 200 miles) for a SQG.

4. HWASs comply with all applicable federal, state, local and FGS accumulation requirements, including proper waste segregation.

Installation Supplement – Accumulation Area Management

Approval to Accumulate Hazardous Waste and Receive Containers

RCRA, Tinker AFB’s RCRA Permit and Air Force instructions require hazardous waste to be tracked from the point of generation to ultimate disposal, or cradle-to-grave. Because improper management of hazardous waste could result in serious consequences to Tinker AFB, and to the individuals involved, any accumulation must be approved through the following procedures:

Requesting Approval to Accumulate Waste or Modify Existing Waste Streams

• The generating shop will contact their organization's UEC and identify the requirement for creation or modification of a waste site. UEC will contact the Hazardous Waste Program Manager (HWPM) to see if a new IAP must be established or if any waste can be incorporated into an existing waste stream. For creation of a new IAP, UEC will provide the following items to HWPM:

o Name and symbol of generating organization o Hazardous Materials Shop Code for generating shop o Building and post location of potential IAP o Primary and Alternate Waste Site Managers names and phone numbers.

o Description of waste that will be generated including volume and frequency o Listing of hazardous materials approved for use by the generating activity o Description of the process generating the waste

• HWPM will review all provided information, request additional information as deemed necessary. HWPM will then enter all information into HWTS, assign appropriate profiles and container types, and will respond to UEC with approval/disapproval to accumulate waste. All approved waste accumulation sites will be listed in Tinker AFB’s HWTS.

Collection Point (CP) Operating Requirements

Some organizations at Tinker AFB manage a particular process at several different locations, each of which generates only small amounts of the same hazardous waste. This management method provides for small containers, 10-gallons or less in size, to collect those wastes at each location and then be emptied into a centrally located IAP, controlled by that organization, at the end of each work shift or when full, whichever comes first.