Appendix G1 HWMP.pdf

HAZARDOUS WASTE MANAGEMENT PLAN

PUERTO RICO AIR NATIONAL GUARD

156th Airlift Wing

Carolina, Puerto Rico

Final

January 2016

Hazardous Waste Management Plan – Final September 2016 156th Airlift Wing Puerto Rico Air National Guard Page i

For Reference Purposes Only Document current version is available at the Environmental Management Office (EMO).

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LETTER OF INSPECTION/APPROVAL

September 2016

MEMORANDUM FOR: 156 AW, PR ANG

FROM: 156 AW/EMO

SUBJECT: Hazardous Waste Management Plan

1. The Hazardous Waste Management Plan (HWMP) is designed to give all waste generators guidance on proper management of hazardous waste.

2. This plan provides operational support for Air Force Instruction 32-7042, 156th Airlift

Wing (156 AW) directives, and other Department of Defense (DoD) hazardous waste directives, 40 Code of Federal Regulation 260-279 and the Commonwealth of Puerto Rico, Environmental Quality Board (EQB) regulations.

3. This plan has been reviewed by members of the Environmental Safety and Occupational

Health (ESOH) Council and the Senior Staff.

4. The plan is effective upon receipt. Shop supervisors should review the plan, ensuring to focus on Chapters 3 and 5.

5. The Office of Primary Responsibility (OPR) for this document is 156 AW/Environmental

Management Office (EMO).

6. As you use this guide, realize federal and state requirements may change, necessitating changes to the plan. If you find conflict between the material in this plan and other official guidance, bring the matter to the attention of the EMO.

Edward L. Vaughan, Col PRANG

Commander

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SIGNATORY AND AUTHORIZATION LETTER

September 2016

MEMORANDUM FOR: 156 AW, PR ANG

FROM: 156 AW/CC

SUBJECT: Delegation of Authority

1. This letter is to designate the following personnel as authorized to sign hazardous waste manifests and hazardous waste profile sheets:

TSgt Ismael Rodriguez, Prime BEEF Manager Civ Marcelle M. Fábregas, Environmental Manager SMS Edwin Acevedo, AGE Superintendent MSgt Javier Ramirez, AGE Power Support Mechanic Support

2. This delegation of authority is in accordance with Defense Reutilization and Marketing Manual 4160.21-M. section F3.

Edward L. Vaughan, Col PR ANG

Commander

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INFORMATION, EMERGENCY AND REGULATORY CONTACTS

The following list provides emergency phone numbers for personnel and/or agencies that may be required to furnish assistance in case of a spill or emergency.

REPORT ON-BASE EMERGENCIES TO

Base Fire Department – From Installation Land Line 911 Base Fire Department – From Cellular Phone (787) 253-5222 Command Center (787) 253-5222

REPORT OFF-BASE EMERGENCIES INVOLVING AIR FORCE ASSETS TO

Fire, Medical, & Police 911

ANG Crisis Action Team (CAT) (24-Hour Service)

(240) 612-7492

(240) 612-7486

ANG Civil Engineering Environmental (CEV) (240) 612-8767 ANG/Bioenvironmental (240) 612-8555

ANG/Safety (703) 607-2196

The Adjutant General (TAG)

(787) 289-1631

DSN 683-3001

FOR CHEMICAL EMERGENCY INFORMATION AND ASSISTANCE

CHEMTREC (800) 424-9300

FOR FEDERAL, STATE, AND LOCAL RELEASE NOTIFICATION/REPORTING

San Juan Departamento de Salud (787) 274-7676

Puerto Rico Emergency Management Agency (PREMA) (787) 725-7019/ /(787) 724-0124

Puerto Rico Environmental Quality Board (787) 767-8056

National Response Center (NRC)

(800) 424-8802

“The Call Center”

Toxics Release Inventory (TRI) Program

Risk Management Program (RMP-Clean Air Act violations)

Oil Pollution Prevention (SPCC,FRP, CWA, OPA regulations)

EPA Response RCRA & EPCRA Hotline (800) 424-9346

Caribbean Environmental Protection Division (787) 977-5869

FOR ON-BASE ASSISTANCE AND INFORMATION

Environmental Manager 9293

FOR OFF-BASE ASSISTANCE AND INFORMATION

Defense Logistics Agency - Disposition Services (DLA-DS) Jacksonville, FL

(904) 942-3759 Ex; 102, or

DSN 942-3759 Ex: 110

EPA Region 2 Hazardous Waste Program Management Office (212) 637-4145

EPA Superfund, Toxics Release Inventory (TRI) Program,, Emergency Planning Community Right-to-Know Act (EPCRA), Risk Management Program (RMP) and Oil Information Center Hotline

(800) 424-9346

Toxic Substances Control Act (TSCA) & Asbestos Technical Information and Referral

(202) 554-1404

National Pesticide Telecommunications Network (800) 858-7378

Hospital – Hospital UPR Carolina (787) 757-1800

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RECORD OF ANNUAL REVIEW & CHANGES

The HWMP will be reviewed annually by the installation EMO. The Record of Annual Review table on the following page provides a mechanism for documenting when and by whom the review occurred. The following issues are to be addressed when conducting the review.

1. Any changes in the types or volumes of wastes generated by organizations at the installation or changes in hazardous materials management procedures that have not yet been documented in the plan.

2. All changes of Points of Contact (POC) listed in this plan should be included in the Annual Review along with any changes associated with both on-installation and off-installation contractors utilized by the Installation.

3. Changes in United States Air Force (USAF), EPA, Occupational Safety and Health Administration

(OSHA), state, and local regulations and policies should be reviewed to identify where the plan may require modification.

4. The plan should be revised and coordinated through applicable installation organizations.

5. The person responsible for conducting the review should include their name, date, and remarks to the Record of Annual Review.

6. Copies of revisions should be distributed to all organizations who received original plans along with any new organizations that are included in the plan. Instruction should be provided on how to integrate revisions to the plan.

7. New organizations to the installation or organizations required to be included in the HWMP will be briefed concerning the proper usage of and instruction to update this plan.

When changes to the HWMP are made (either as a result of the Annual Review or between such reviews), these changes will be recorded on the Record of Changes table on the following page. This will allow the Base to track the changes made to the HWMP over time to show adherence to changes in regulatory requirements, staffing, or other related issues.

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RECORD OF ANNUAL REVIEW

Reviewer Date Reviewed Remarks

ANGB Contract- BEM System April 2013 Five-year review

Marcelle M Fábregas, EMO January 2014 Update information on plan

Marcelle M Fábregas, EMO January 2015 Update information on plan/ New Commander

Marcelle M Fábregas, EMO January 2016 Update information on plan/ New Commander

Marcelle M Fábregas, EMO September 2016 Authorization Letter/ Update

RECORD OF CHANGES

Change Number/ Applicable Section/Page #

Effective Date Posted By

1. Signatory and Authorization Letter/ Update names/ Page iii January 2014 MMF

2. Executive Summary/ Added VEMO website link/ Page ix January 2014 MMF

3. Introduction/ Update tenants information/ Page 1 January 2015 MMF

4. Table 3-1/ Change SAP Numbers/ Appendix 4 January 2015 MMF

5. Table 3-1/ Update personnel names/ January 2015 MMF

6. Section 5.5/ Update Disposition Servicer information/ Page 53 January 2015 MMF

7. Table 3-3/ Change Waste Stream Numbers/ Appendix 4 January 2015 MMF

8. Table 3-3/ Change Waste Profiles Numbers/ Appendix 4 January 2015 MMF

9. Introduction / Update GSU’s information/ Page 1 and throughout plan January 2015 MMF

10. Commonwealth of PR Regulations/ Update agency address/ Page 9 January 2015 MMF

11. Specific Responsibilities/ Update information/ Pages 11-19 January 2015 MMF

12. Signatory and Authorization Letter/ Update names/ Page iii January 2016 MMF

13. Executive Summary/ Update regulations information/ Page viii January 2016 MMF

14. Summary of RCRA HW Requirements/Correct EPA ID No./ Page 3 January 2016 MMF

15. Authorization Letter/ Update names/ Page iii September 2016 MMF

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EXECUTIVE SUMMARY

The Air National Guard (ANG) is committed to proper management of Hazardous Waste (HW) generated on all installations throughout the nation. The primary objective of this Hazardous Waste Management

Plan (HWMP) is to provide a management plan that gives personnel involved with HW the essential tools for effective management.

This HWMP is a base-specific document that provides guidance to personnel who work with hazardous waste, and sets local management procedures for managing hazardous waste and preventing pollution. The plan incorporates current ANG, United States Environmental Protection Agency (EPA), Occupational

Safety and Health Act/Occupational Safety and Health Administration (OSHA), State, and local requirements regarding the management of hazardous waste as they relate to environmental protection and worker safety during operations conducted at this base.

This HWMP also prepared in compliance with Air Force Instruction (AFI) 32-7042 Waste Management, dated 7 November 2014. AFI 32-7042 requires that all installations prepare a HWMP. The HWMP also complies with AFI 32-7086, Hazardous Materials Management, dated 4 February 2015, Air Force Records

Information Management System (AFRIMS) (record keeping requirements), and AFI 32-7001

(Environmental Management) dated 16 April 2015. The HWMP must reflect current regulatory requirements and installation HW activities.

Finally, the HWMP complies with recordkeeping provisions enumerated in AFRIMS requires the retention of hazardous waste records for 50 years as described in this plan, a retention period that is more stringent than either Federal or Commonwealth requirements. This HWMP is applicable to all facets of operations conducted at the 156th Airlift Wing (AW) of the Puerto Rico Air National Guard (PR ANG). The Plan has been developed to ensure that the facility has guidance pertaining to all aspects of HW management in order to facilitate compliance with all Federal, State, and local regulations. The scope of this HWMP includes the following elements required by AFI 32-7042:

• Letter of Instruction

• Record of HWMP Annual Review

• Record of HWMP Changes

• Delineation of HW Management Responsibilities

• Installation Organization

• HW Inventory

• Waste Analysis Plan (WAP)

• HW Management Procedures

• Reporting and recordkeeping

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• HW Training Requirements

• Contingency Plan Summary

• Preparedness and Spill Prevention Summary

• Pollution Prevention Summary

The HWMP must be kept current to reflect changes in regulatory requirements or waste activities conducted at the base. At a minimum, the plan must be reviewed annually by the base Environmental Management

Office (EMO) and updated as needed. Pertinent information of the updated plan shall be provided to the relevant activity which is involved in the use of hazardous materials or generation of hazardous waste. The official version of this plan is on the VEMO SharePoint site at the following address:

https://eis.ang.af.mil/func/VEMO/muniz/Pages/default.aspx.

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TABLE OF CONTENTS

SECTION PAGE NO.

1.0 INTRODUCTION

1.1 Base Location and Background

1.2 Objective

1.3 Applicability & Implementation

1.4 Regulatory Overview

1.4.1 Summary of RCRA Hazardous Waste Requirements

1.4.2 Commonwealth of Puerto Rico Regulations

1.4.3 Supplemental Regulations

2.0 DELINEATION OF RESPONSIBILITIES

2.1 Tasked Organizations

2.2 Specific Responsibilities

2.2.1 Installation Commander

2.2.2 Environmental Safety & Occupational Health Council

2.2.3 Environmental Management Office

2.2.4 Civil Engineering Squadron

2.2.5 Logistics Office

2.2.6 Finance Management and Accounting Office

2.2.7 Contracting Officer

2.2.8 Defense Logistics Agency – Disposition Services

2.2.9 Shop Supervisors

2.2.10 Hazardous Waste Generators

2.2.11 Satellite Accumulation Point Managers

2.2.12 Central Accumulation Point Managers

2.2.13 Public Affairs Office

2.2.14 Ground Safety

2.2.15 Tenant Organizations/Contractors

2.2.16 Public Health Office

2.2.17 Bioenvironmental Engineering Technician

2.2.18 Air National Guard/Civil Engineering Environmental

2.2.19 The Adjutant General/Judge Advocate General

3.0 HAZARDOUS WASTE INVENTORY AND LOCATIONS

3.1 Hazardous Waste Generation Points

3.2 Satellite Accumulation Points

3.3 Central Accumulation Point

3.4 Hazardous Waste Stream Inventory

3.5 Non-Hazardous Waste Stream Inventory

4.0 WASTE ANALYSIS PLAN

4.1 Hazardous Waste Characterization Process

4.1.1 Waste Identification

4.1.2 Hazardous Waste Evaluation

4.1.3 Results Interpretation and Documentation

4.2 Sampling And Analysis Location And Frequency

4.2.1 Initial Characterization and Analysis of Waste Streams

4.2.2 Periodic Partial Analysis of Waste Streams

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4.2.3 Detailed Analysis for Specific Components of Waste Streams

4.2.4 Other Waste Streams

4.2.5 Unknown Waste Streams and Residuals in Containers

4.2.6 Sample Frequency

4.3 Test Methods Used

4.4 Analytical Methods

4.5 Hazardous Waste Sampling Methods

4.5.1 Sampling Liquid Substances

4.5.2 Sampling Sludges

4.5.3 Sampling Solid Substances

4.5.4 Obtaining Samples of Rags and Absorbent Pads from Containers

4.5.5 Other Sampling Procedures

4.5.6 Sample Preservation

4.6 Sample Documentation

4.7 Sample Request Procedures

4.8 Hazardous Waste Profile Sheet

4.9 Waste Analysis Plan Revision

4.10 Quality Assurance/Quality Control Procedures

4.10.1 Methods

4.10.2 Analytical Quality Assurance

5.0 HAZARDOUS WASTE MANAGEMENT PROCEDURES

5.1 Identification Of Hazardous Waste

5.2 Packaging And Labeling

5.2.1 Packaging

5.2.2 Labeling

5.3 Satellite Accumulation Point Management

5.4 Central Accumulation Point Management

5.4.1 Siting

5.4.2 Container Management

5.4.3 CAP Labeling Requirements

5.4.4 Inspections

5.4.5 CAP Container/Inventory Log

5.4.6 CAP Training

5.4.7 Emergency Response Equipment

5.4.8 Recordkeeping Requirements

5.5 Hazardous Waste Turn-In Procedures

5.5.1 DLA-DS Turn-In Procedures

5.5.2 Independent Contractor Recommended Turn-in Procedures

5.6 Management of Commonly Generated Waste Streams

5.6.1 Universal Waste Management

5.6.1.1 Batteries

5.6.1.2 Lamps

5.6.1.3 Manifests/Transportation

5.6.1.4 Labeling

5.6.1.5 Accumulation Times

5.6.1.6 Training and Other Regulations

5.6.2 Electronic Items

5.6.3 Solvent-/Oil-Contaminated Rags

5.6.4 Oil Filters

5.6.5 Ballasts and Switches

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5.6.6 Lead

5.6.7 Aerosol Cans

5.6.8 Paint Cans, Paint Brushes, and Related Materials

5.6.9 Used Oil

5.6.10 Silver Recovery

5.6.11 Medical Wastes

5.6.12 Management of Empty Drums

5.7 Transportation Requirements

5.7.1 On-Installation Transportation

5.7.2 Off-Installation Transportation

5.7.3 Instructions for Completion of the Manifest

5.7.4 Notification and Certification Required by the Land Disposal Restrictions

5.7.5 Exception Reports

5.7.6 Discrepancy Reports

5.7.7 Transporter Reports

5.7.8 Additional Transportation Requirements

5.8 Off-Installation Management of Hazardous Waste

6.0 REPORTING AND RECORDKEEPING

6.1 Hazardous Waste Manifests

6.2 Hazardous Waste Records

7.0 TRAINING

7.1 Training Requirements

7.2 Training Responsibilities & Execution

7.3 Training Documentation

8.0 EMERGENCY RESPONSE

8.1 General Emergency Response Procedures

8.2 Incident Commander Emergency Response Procedures

9.0 POLLUTION PREVENTION

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APPENDICES

Appendix 1 Base Location Figures

Figure 1-1: Location of 156 AW, 141 ACS, 140 SPTS and 285 CES Figure 3-1: 156th Airlift Wing Hazardous Waste Accumulation Points Figure AI-1: HW Accumulation Points for the 141st Air Control Squadron, Punta Borinquen Figure AII-1: HW Accumulation Points for the 140th Support Squadron, Punta Salinas Figure AIII-1: HW Accumulation Points for the 285th Civil Engineering Squadron, St. Croix, U.S. Virgin Islands

Appendix 2 Definitions and Acronyms

Appendix 3 Inspection and Request Forms

Form 1: Example Hazardous Waste Contractor Evaluation Form Form 2: Example Central Accumulation Point Weekly Inspection Checklist Form 3: Example Central Accumulation Point Container/Inventory Log Form 4: Example Universal Waste Tracking Log Form 5: Example Response Notification (Form 19-1) Table 9-1: Sample List of Emergency Response Equipment

Appendix 4 Accumulation Points and Waste Stream Inventory

Table 3-1: Hazardous Waste Satellite Accumulation Points Table 3-2: Hazardous Waste Central Accumulation Point Table 3-3: Current Hazardous Waste Stream Inventory

Appendix 5 Hazardous Waste Identification and Waste Stream Sampling

Figure 4-1: Hazardous Waste Determination Process Memorandum for Waste Generators Figure 4-2: Identification of Hazardous Waste Figure 4-3: Example Non-Hazardous Sample Confirmation Letter Figure 4-4: Example Hazardous Sample Confirmation Letter Figure 4-5: Example Hazardous Waste Profile Sheet Form 7: Toxicity Characteristic List

Appendix 6 Labeling Information

Figure 5-1: Example of DOT Title 49 CFR 172.101 HM Table Figure 5-2: Hazard Classes Figure 5-3: Standard Hazardous Waste Label Example Figure 5-4: Potentially Incompatible Wastes Figure 5-5: Can Puncturer Authorization Figure 5-6: Uniform Hazardous Waste Manifest

Appendix 7 Training Materials

Table 7-1: Training Matrix Figure 7-1: Example Satellite Accumulation Point Manager Training

Appendix 8 Standard Operating Procedures

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1.0 INTRODUCTION

1.1 Base Location and Background

The 156th Airlift Wing (156 AW) of Puerto Rico Air National Guard (PR ANG) is located at the Muñiz Air

National Guard Base (ANGB), adjacent to the Luis Muñoz Marin International Airport, in the Carolina region east of San Juan, Puerto Rico. Figure 1-1 depicts the location of the 156 AW. The installation occupies approximately 95 acres and is leased from the Puerto Rico Ports Authority. The 156 AW has 303 full time personnel and approximately 1,135 Unit Training Assembly (UTA) active Guard Reservists. The

156 AW presently flies and maintains six (6) C-130 aircraft in support of its mission.

The mission of the 156 AW is to train and maintain assigned mission-ready aircrews and support personnel to mobilize and deploy anywhere in the world. This mission includes delivery of personnel, equipment and supplies by either single ship or formation, in favorable or adverse weather conditions, on prepared surfaces or unpaved landing strips, using airdrop or air land procedures. In addition, the 156 AW supports permanently-assigned aircraft and provides services to transient military and governmental aircraft. The

ANG Installation also provides support for tenant activities assigned to the installation, if necessary.

The primary function of the ANG installation is to operate and maintain aircraft. To meet this function, the

Installation provides facilities where personnel refuel, maintain, and perform light repairs on the aircraft.

To support these functions, the Installations comprise facilities for the maintenance of vehicles and other support equipment; facilities and staff for the maintenance of structures, roadways, and grounds; a number of administrative and security –based small office buildings and a supply and shipping warehouse.

Three (3) Geographically Separate Units (GSUs) are associated with the 156 AW. These are the 141st Air

Control Squadron (141 ACS), located at Punta Borinquen, near the town of Aguadilla, Puerto Rico; the 140th

Support Squadron (140 SPTS), located at Punta Salinas in the municipality of Toa Baja, Puerto Rico; and the 285th Civil Engineering Squadron (285 CES), located on the island of St Croix, U.S. Virgin Islands, near the Alexander Hamilton International Airport, southwest of Christiansted.

Site-specific information pertaining to these GSUs is provided in the HWMP as follows:

141 ACS - Attachment I;

140 SPTS - Attachment II, and

285 CES - Attachment III

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The stated mission of the 156 AW is to provide disaster relief in the event of natural calamity, maintain public peace and order, and support civil defense and pre-attack planning, as directed by the Governor of

Puerto Rico.

The delineation of personnel responsibilities for implementation of this HWMP is contained in Chapter 2, Section 2.2. Definitions of the terms and acronyms used in this document are presented in Appendix 2.

1.2 Objective

The 156 AW is committed to proper management of the hazardous waste (HW) generated on all of the installation and its GSUs. The primary objective of this document is to provide a management plan that gives personnel involved with HW the essential tools for effective management.

1.3 Applicability & Implementation

This HWMP is applicable to all facets of operations conducted at the Base. The plan has been developed to ensure that the installation has guidance pertaining to all aspects of HW management in order to facilitate compliance with all federal, state, and local regulations. The scope of this HWMP includes the following elements:

The delineation of HW management responsibilities;

HW inventory;

Waste Analysis Plan (WAP) and Sampling Procedures;

Waste management procedures, including, reporting, training, and recordkeeping;

Emergency response/preparedness and spill prevention; and

Pollution prevention & hazardous material (HM) pharmacy program development.

This plan addresses key issues in implementing the complex area of HW management required by the

Resource Conservation and Recovery Act (RCRA), as enforced by the United States Environmental

Protection Agency (EPA), at federal facilities such as the 156 AW. Federal facilities are not exempt from the requirements of this law.

1.4 Regulatory Overview

The RCRA, enacted in 1976, is the government’s primary statute for controlling HW and protecting the environment and the public’s health from its effect. Through the EPA HW regulations (located in Title 40

Code of Federal Regulations [CFR] Parts 260-280) it establishes a regulatory process that controls HW from “Cradle to Grave,” which is from the moment of HW generation until the wastes are shown to no longer be hazardous. ANG installations that generate, store, treat, or dispose of HW are required to be aware of EPA regulations that apply to their activities and wastes.

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1.4.1 Summary of RCRA Hazardous Waste Requirements

RCRA has ten Subtitles (A-J), each of which addresses some aspect of resource conservation and waste management. Subtitle C is the primary portion of RCRA that deals with the management of HW. The goal of Subtitle C is to identify HW and to establish standards for the accumulation, transportation, storage, treatment, and disposal of HW. Consequently, the provisions of Subtitle C apply to a waste the moment it becomes “a HW” until it is no longer a HW.

The 156 AW, 141 ACS and 140 SPTS are regulated under EPA and Puerto Rico Environmental Quality

Board (EQB) HW regulations. The 285 CES is regulated under EPA and U.S. Virgin Islands Department of Planning and Natural Resources (USVI DPNR) HW regulations. EPA HW Identification (ID) numbers and generator status for each of the units is as follows:

156 AW is regulated as a small quantity generator (SQG) of HW and maintains EPA HW ID number PR9570099516;

140 SPTS in Punta Salinas is regulated as a conditionally exempt small quantity generator

(CESQG) and has been assigned an EPA ID number of PR7572899998;

141 ACS at Punta Borinquen is regulated as a CESQG and has been assigned an EPA ID number of PR6572899999;

285 CES at St. Croix, USVI is regulated as a CESQG and has been assigned an EPA ID number of

VI0109796342.

Table 1-1 provides an illustration of the various regulatory requirements for a SQG and CESQG of HW.

Table 1-1: Federal Regulatory Requirements for SQGs and CESQGs

TOPIC SQG REQUIREMENT CESQG REQUIREMENT

Quantity Limits 100-1000 kg/mo.

(220 – 2200 lbs)

100 kg/mo.

<220 lbs one (1) kg/month of acute HW

100 kg/month of acute spill residue or soil

Management of Waste RCRA-regulated facility State-approved, RCRA regulated

Manifest Required Not required

Retain signed copies of manifests for three (3) years

Required Not required

Attach Land Disposal Restriction Report notification form to each manifest and retain copies of LDR determinations for three (3) years

Required Not required

Exception Report Required 60 days1 Not required

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TOPIC SQG REQUIREMENT CESQG REQUIREMENT

Biennial Report Not required Not required

Personnel Training Basic training required Required

(AFI/ANG)

Inspections Containers in CAPs weekly Not required

Contingency Plan Basic plan required

The Emergency Coordinator must be able to respond to spills, fires, and releases per 40CFR 262.34(d)(5)(ii) as discussed in

HWMP Section 8 and employees must be familiar with waste handling and emergency response procedures

Not required

EPA ID Number Required Not required

Onsite Accumulation Limits 180 days or 270 days ( 200 miles)

< 1,000 kg < 1 (one) kg acute

< 100 kg spill residue from acute

No time limit

Storage Requirements Full compliance with management of containers or tanks

None

1In Puerto Rico, both SQG and LQGs who do not receive the original signed copy of the manifest within a period of twenty (20) days from the date the initial transporter accepted the waste, must contact the transporter and the owner or operator of the designated facility to determine the status of the hazardous solid waste. The SQG or LQG must submit an Exception Report to the EQB if a copy of the manifest is not received within thirty (30) days of the date the waste was accepted by the initial transporter.

The Base and the three associated GSUs are small quantity handlers of universal waste (SQHUW), a subdivision of HW that does not need to be managed as a HW as long as the provisions of Universal Waste

(UW) Management, the Universal Waste Rules (UWR), established in 40 CFR 273 are followed. In May

2012, the EQB of the Commonwealth of Puerto Rico published a Notification and Resolution, R-12-9, authorizing batteries, pesticides, mercury-containing equipment and lamps to be managed as UW in accordance with the UWR. Prior to this notification, the above-mentioned wastes were managed as fully regulated HW in Puerto Rico. The USVI DPNR has not adopted the UWR, therefore, wastes considered to be UW in the United States and Puerto Rico, must be fully managed as HW in the USVI.

1.4.2 Commonwealth of Puerto Rico Regulations

The EQB received authorization from EPA to regulate the RCRA HW program for the Commonwealth of

Puerto Rico. The Regulations governing HW Management in Puerto Rico (Reglamento para el Control de los Desperdicios Sólidos Peligrosos) pertain to the generation, transportation, storage, treatment, disposal, and management of HW within Puerto Rico. The majority of the Puerto Rico HW regulations incorporate by reference the federal RCRA HW regulations found in 40 CFR 260 through 268, 273, and 279. Table 1-

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2 presents a comparison between the Puerto Rico HW regulations and the federal HW regulatory counterparts in 40 CFR.

At the Commonwealth level, in accordance with the Environmental Public Policy Act, No. 9 of 1970, as amended by Law 416, the Puerto Rico EQB was created to establish a public policy that encourages a desirable and convenient harmony between man and his environment, to promote efforts to prevent or eliminate damage to the environment, to promote efforts to prevent or eliminate damage to the environment and to preserve the health and welfare.

The Puerto Rico EQB regulations can be found at the following website: http://www.jca.pr.gov/

Table 1-2: Comparison of Puerto Rico and Federal Hazardous Waste Regulations

Chapter Description Similar to 40

CFR

40 CFR Part Title

PART I

DEFINITIONS AND

ABBREVIATIONS

Rule 101 Purpose, Scope and Applicability portions of 261 Identification and Listing of Hazardous Waste

Rule 102 Definitions Not Applicable Not Applicable Rule 103 Acronyms Not Applicable Not Applicable

PART II GENERAL PROVISIONS

Rule 201 Title Not Applicable Not Applicable Rule 202 Purpose, Scope and Applicability Not Applicable Not Applicable Rule 203 Effective Date Requirements Not Applicable Not Applicable Rule 204 Monitoring and Maintenance of

Records, Sampling and Analytical Methods

Not Applicable Not Applicable

Rule 205 Right to Enter to Inspect and Review Not Applicable Not Applicable Rule 206 Information Available to the Public Not Applicable Not Applicable Rule 207 Plan of Operation Not Applicable Not Applicable Rule 208 Revision of Applicable Rules and

Regulations portions of 260 Hazardous Waste Management System:

General Rule 209 Mandatory Public Hearings on the

Regulation Not Applicable Not Applicable

Rule 210 Public Hearings and Public Notices Not Applicable Not Applicable Rule 211 Notice of Violations and Compliance

Orders Not Applicable Not Applicable

Rule 212 Closure of a Solid Waste Facility or of a Generating Activity

Not Applicable Not Applicable

Rule 213 Penalties and Revocation of Permits Not Applicable Not Applicable Rule 214 Public Nuisance Not Applicable Not Applicable Rule 215 Legal Actions of Citizens Not Applicable Not Applicable Rule 216 Conflicting or Contradictory

Provisions Not Applicable Not Applicable

Rule 217 Exceptions Rule 218 Clause of Severability Not Applicable Not Applicable

|PART V SPECIAL REQUIREMENTS FOR

THE MAINTENANCE OF

RECORDS AND REPORTS FOR

GENERATORS, TRANSPORTERS,

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Similar to 40

CFR

40 CFR Part Title

AND OWNERS OR OPERATORS

OF HAZARDOUS SOLID WASTE

FACILITIES

Rule 501 Purpose, Scope and Applicability

Not Applicable Not Applicable

Rule 502 Maintenance of Records for Facility Operations or Activities

265 Interim Status Standards for Owners and Operators of Hazardous Waste, Treatment, and Disposal Activities

Rule 503 Reporting for Facility Operations and Activity portions of 262 and 265

Standards Applicable to Generators of Hazardous Waste and Interim Status Standards for Owners and Operators of Hazardous Waste, Treatment, and Disposal Activities

Rule 504 Maintenance of Records and Reports on the Manifest System portions of 263 and 265

Standards Applicable to Transporters of Hazardous Waste and Interim Status Standards for Owners and Operators of Hazardous Waste, Treatment, and Disposal Activities

Rule 505 General Provisions Regarding the Maintenance of Records and Reports portions of 262 Standards Applicable to Generators of Hazardous Waste

PART VI CLASSIFICATION AS

HAZARDOUS SOLID WASTE

Rule 601

Purpose, Scope and Applicability

Rule 602 Requirements for Evaluation of Hazardous Solid Waste

Not Applicable Not Applicable

Rule 603 Criteria for Classification of Hazardous Solid Waste portions of 261 Identification and Listing of Hazardous Waste

Rule 604 Characteristics of Hazardous Solid Waste portions of 261 Identification and Listing of Hazardous Waste

Rule 605 Extremely Hazardous Solid Waste Not Applicable Not Applicable Rule 606 Special Requirements for Certain

Hazardous Wastes portions of 261 Identification and Listing of Hazardous

Waste Rule 607 List of Hazardous Wastes portions of 261 Identification and Listing of Hazardous

Waste Rule 608 List of Hazardous Solid Wastes Not Applicable Not Applicable Rule 609A Changes to the Classification of Solid

Waste portions of 260 Hazardous Waste Management System:

General

Rule 609B Standards and Criteria for the Changes in Classification of Solid Waste portions of 260 Hazardous Waste Management System:

General

Rule 610 Rule Change to Qualify as a Boiler portions of 260 Hazardous Waste Management System:

General

Rule 611 Procedures for Changes in Classification of Solid Waste or to be Qualified as a Boiler portions of 260 Hazardous Waste Management System:

General

Rule 612 Additional Regulation for Certain Activities of Hazardous Waste portions of 260 Hazardous Waste Management System:

General

156th Airlift Wing Puerto Rico Air National Guard Page 7

Similar to 40

CFR

40 CFR Part Title

Recycling on Case-by-Case Applicability

Rule 613 Procedures for Case-by-Case Regulation of Hazardous Waste Recycling Activities portions of 260 Hazardous Waste Management System:

General

PART VII SPECIFIC PROVISIONS

RELATING TO GENERATORS

AND TRANSPORTERS OF

HAZARDOUS SOLID WASTE

Rule 701 Purpose, Scope and Applicability

Rule 702 Standards for Hazardous Solid Waste Generators portions of 262 Standards Applicable to Generators of Hazardous Waste

Rule 703 Use of Manifest System by Generators and Transporters of Hazardous Solid Waste portions of 262 Standards Applicable to Generators of Hazardous Waste

Rule 704 Pre-Transportation Requirements for Hazardous Solid Waste Generators portions of 262 Standards Applicable to Generators of Hazardous Waste

Rule 705 Special Requirements for Certain Generators of Hazardous Solid Waste portions of 262 Standards Applicable to Generators of Hazardous Waste

Rule 706 Specific Provisions Applicable to the Transportation of Hazardous Solid Waste portions of 263 Standards Applicable to Transporters of Hazardous Waste

Rule 707 Emergency During Transportation portions of 263 Standards Applicable to Transporters of Hazardous Waste

PART VIII SPECIAL PROVISIONS FOR

FACILITIES

SUBPART I Treatment, Storage and Disposal of Hazardous Solid Wastes portions of 265 Interim Status Standards for Owners and Operators of Hazardous Waste, Treatment, and Disposal Activities

SUBPART II Treatment, Storage and Disposal of Hazardous Solid Wastes portions of 264 Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities

PART IX PERMITS TO BUILD AND

OPERATE FACILITIES

SUBPART I SERVICES AND ACTIVITIES FOR

HAZARDOUS SOLID WASTE;

COMPLIANCE PLANS; WAIVERS

portions of 270 EPA Administered Permit Programs: The Hazardous Waste Permit Program

PART X PERMIT FEES Not Applicable Not Applicable

PART XI RULES FOR THE MANAGEMENT

OF SPECIFIC HAZARDOUS

WASTES AND SPECIFIC TYPES

OF FACILITIES FOR HAZARDOUS

WASTE MANAGEMENT

266 Standards for the Management of Specific Hazardous Waste and Specific Types of Hazardous Waste Management Facilities

No comparable regulation

No comparable regulation 268 Land Disposal Restrictions

CHAPTER VII

Regulation for Handling of

Provisions for Management of Used Oil

279 Standards for the Management of Used Oil

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Similar to 40

CFR

40 CFR Part Title

Non-Hazardous Solid Waste Resolution R- 12-9

Resolution and Notification R-12-9 273 Standards for UW Management

Significant differences between the Puerto Rico HW regulations and the federal HW regulations are listed below:

Per the Reglamento para el Control de los Desperdicios Sólidos Peligrosos, Rule 504(A) & Rule 703(F), if a generator does not receive a copy of the manifest signed by the facility owner/operator of the designated disposal facility within twenty (20) days of the date the waste was accepted by the initial transporter, the generator must contact the transporter and facility owner/operator of the designated facility to determine the status of hazardous solid waste. If the generator does not receive the original signed copy of the manifest within a period of thirty (30) days from the date the initial transporter accepted the waste, the generator must submit an Exception Report to the EQB. 40 CFR 262.42 allows for sixty (60) days to pass after the date the waste was accepted by the initial transporter to submit an Exception Report for SQGs.

The above requirements do not apply to a an SQG when the waste is reclaimed under a contractual agreement pursuant to which:

1) The type of waste and frequency of shipments are specified in the agreement;

2) The vehicle used to transport the waste to the recycling facility and to deliver regenerated material back to the generator is owned and operated by the reclaimer of the waste; and

3) The generator maintains a copy of the reclamation agreement in his files for a period of at least three years after termination or expiration of the agreement.

Per the Reglamento para el Control de los Desperdicios Sólidos Peligrosos, Rule 705(B), when shipping HW from Puerto Rico to the U.S. or USVI, the generator must send one (1) copy of the manifest to the EPA and one (1) copy to the appropriate state regulatory agency having jurisdiction over the facility designated to receive the HW. If the waste is transported as a bulk shipment by a sea-going vessel, the generator must send a copy of the shipping documents to EPA and the appropriate state agency having jurisdiction over the facility designated to receive the HW. The generator must require the designated receiving facility to provide a copy of the completed and signed manifest to the EQB, the EPA and the appropriate state agency having jurisdiction over the facility designated hazardous solid waste. The generator must register an Exception Report to the EQB, the EPA, and the State in which the facility is located and any other State to which the shipment could have been sent if a copy of a fully executed and signed manifest is not received within 45 days of transfer of the waste by the initial transporter.

The standard manifest system (which contains eight (8) copies) must be signed by the generator who delivers a hazardous solid waste to a transporter. It shall also be signed by the transporter, acknowledging receipt of the hazardous solid waste that is going to be transported. The generator shall, then send copy #7 of the manifest to the EQB and copy #6 to the State where the waste will be stored, treated, or disposed of (within one (1) week of the waste delivery to the transporter)

156th Airlift Wing Puerto Rico Air National Guard Page 9 and will retain copy #8 as a record. The SQG must submit the Manifest Copy to the Director of Area for Land Pollution Control, Environmental Quality Board, Edificio de Agencias Ambientales Cruz A. Matos Urbanización San José Industrial Park 1375 Avenida Ponce de León San Juan, PR 00926-2604

1.4.3 Supplemental Regulations

The EQB has developed supplemental regulations for Handling of Non-Hazardous Solid Wastes (Reglamento para el Manejo de los Desperdicios Sólidos No Peligrosos) such as used oil, PCBs, special wastes, electronics, and industrial wastes. These regulations provide additional guidance for the Commonwealth’s HW generators and transporters and replace the requirements within Part IV of the Reglamento para el Control de los

Desperdicios Sólidos Peligrosos. Per Reglamento para el Manejo de los Desperdicios Sólidos No Peligrosos, Rule 502, special waste is defined as nonhazardous solid waste containing asbestos, lead, oils, tires or regulated medical waste. Also considered special waste are non-hazardous solid waste that the EQB determines to be special wastes because the quantity, concentration or physical or chemical characteristics require special handling to prevent imminent harm to human health or the environment. Industrial wastes are defined as solid waste generated in industrial processes, including but not limited to: electric power generation; application of fertilizer and chemicals for agricultural purposes; food processing and their derivatives; inorganic chemical, iron and steel manufacturing; production of hides and products; ferrous metal manufacturing, and paper-production pulp; plastics and resins manufacturing; production of rubber and miscellaneous plastic products; production of stone, glass, clay, concrete and cement, textile manufacturing, transportation equipment; water treatment. Biomedical waste is also covered under the

Handling of Non-Hazardous Solid Wastes.

Potential wastes generated by the 156 AW, with the exception of HW, falling into the above-mentioned categories include, but are not limited to:

Construction debris Chemical waste from portable toilets

Asbestos Pharmaceuticals

Some paint waste and filters Cooking grease trap waste

Antifreeze Chemicals labeled “Warning” for toxics

Filters containing solvents/strippers Filters and absorbents with dry cleaning / degreasing solvents

Petroleum contaminated water Mud or sand trap waste

Empty containers over 5 gallons Used oil

Treated or untreated infectious waste Spent solvents, strippers and degreasers

Sewage or other organic sludges Fuel tanks

Textiles Empty containers labeled “Dangerous”

Pressurized containers Fertilizer and agriculture chemicals

Materials containing 25% maximum Toxicity Characteristic Leaching

E-scrap

156th Airlift Wing Puerto Rico Air National Guard Page 10

Procedure (TCLP) of heavy metal or

0.3 mg/l of nickel

If any questions arise about the possibility of a material being a special waste, contact the EMO for assistance in determining how the material should be disposed.

156th Airlift Wing Puerto Rico Air National Guard Page 11

2.0 DELINEATION OF RESPONSIBILITIES

2.1 TASKED ORGANIZATIONS

Responsibilities for implementing this plan have been distributed to Base organizations that generate, treat, accumulate, monitor, dispose, or respond to incidents involving HW. Compliance with federal, state, and local HW laws and regulations is the responsibility of the Installation Commander through the

Environmental Safety and Occupational Health (ESOH) Council. The development, maintenance, and implementation of this plan are the result of a 156 AW ESOH Council action. The following organizations and offices are tasked under this plan:

Installation Commander Environmental Safety & Occupations

Health (ESOH) Council Environmental Management Office

(EMO)

Shop Supervisors HW Generators Satellite Accumulation Point (SAP) Managers and

Alternates

Environmental Manager (EM) Bioenvironmental Engineer/Technician

(BEE-Tech) State Environmental Specialist (SES) Civil Engineering Squadron (CES) Logistics (Supply) Base Fire Department Finance Management and Accounting

Office (FAO) Contracting Officer (CO) Defense Logistics Agency - Disposition

Services(DLA-DS)

Central Accumulation Point (CAP) Managers Public Affairs Office (PAO) Ground Safety Tenant Organizations/Contractors Base Emergency Coordinator (EC) Military Public Health Air National Guard (ANG)/Civil Engineering

Environmental The Adjutant General (TAG) Judge Advocate General (JAG)

2.2 SPECIFIC RESPONSIBILITIES

2.2.1 Installation Commander

The Installation Commander is responsible for ensuring that the management of HW complies with applicable portions of both federal and state environmental regulations. The Installation Commander signs all environmental permits and documents and receives regulatory agency administrative orders levied against the installation. The Installation Commander has the signatory authority for manifests and other regulatory documents. The Installation Commander has primary responsibility for signing the manifest as the generator. The Installation Commander may designate, in writing, other persons with authority to sign manifests and may also allow approved personnel to designate additional signatory authority. The designee of the Defense Logistics Disposition Agency (DLA-DS) representative is the Installation EM. Where DLA-

DS is not the Installation Commander’s designee, a DLA-DS representative will co-sign all manifests for shipments of HW on Defense Logistics Agency (DLA) accountable records.

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Additionally, the Commander assigns personnel to manage the Central Accumulation Point (CAP) and

Satellite Accumulation Point (SAP) Managers recommended by the EMO or shop supervisors.

2.2.2 Environmental Safety & Occupational Health Council

The Installation ESOH Council is the Installation Commander’s mechanism for ensuring compliance with all of the environmental programs. The ESOH Council, chaired by the Installation Commander, convenes semi-annually or in the event of special circumstances, and reviews and coordinates the Commander’s HW management program and all other installation environmental programs. The ESOHC is responsible for reviewing and approving HW policies and reviewing the HWMP, per AFI 32-7042.

2.2.3 Environmental Management Office

The 156 AW EMO is responsible for managing the installation HW management program. The EMO includes the Environmental Manager (EM) and State Environmental Officer (SEO). At the 156 AW, the

EM designates the SEO as the HW Program Manager and the EM directs and oversees the SEO’s work.

The EM may designate the responsibilities described below.

The EMO will provide technical assistance to the SAP manager by providing guidance pertaining to proper labeling procedures, management procedures, and recordkeeping procedures. The EMO will provide HW management training to the accumulation site manager and alternate. The EMO will be responsible for profiling all waste streams at the accumulation sites and making arrangements for the disposal of waste within appropriate time-frames based on generator status. The EMO will complete all required Hazardous

Waste Profile Sheets (HWPSs) (Form 1930) and be responsible for the annual review and update of the profiles. The EMO will provide funding for all supplies required for the management of the site and funding for disposal of the wastes.

Environmental Manager

The EM acts as the installation liaison on environmental compliance matters with regulatory agencies on all HW disposal issues. The EM provides installation technical expertise on HW identification (ID) and is the Office of Primary Responsibility (OPR) for the ANG installation HW stream inventory and WAP. The

EM is also responsible for ensuring that the installation has an updated HWMP, applying for installation

HW permits (if permits are required), providing technical information and assistance to generating activities installation-wide for completion of HW turn-in documents, ensuring that HW management training is provided, and certifying that all HW is properly characterized, labeled, and packaged.

The EMO ensures that HW generated from the ANG installation is weighed for all disposal actions. The

EM requests funds from the Air National Guard/Civil Engineering Environmental (ANG/CEV) through the installation FAO, certifies fund availability for waste turned-in to DLA-DS, and reviews billings received

156th Airlift Wing Puerto Rico Air National Guard Page 13 by the FAO for accuracy, requesting adjustments when necessary. The EM is responsible for collecting, preparing, and providing transportation of samples from unknown waste streams to a certified analytical laboratory for HW analysis. Furthermore, the EM requests procurement of analytical/disposal services, manages all local HW analysis and disposal contracts, manages HW disposal funds, and programs future waste disposal requirements. The EM retains an original and final copy of the HW manifest for verification before payment is made. An example contractor evaluation sample form is illustrated as Form 1 in

Appendix 3.

The EM provides training pertaining to HW management procedures to installation personnel working with processes or chemicals that generate HW. Upon completion of the training, the EM provides individual certificates and keeps copies of these in the personnel files.

If the HW manifest is not received from the Treatment, Storage and Disposal Facility (TSDF), the EM submits an Exception Report to the state environmental agency or to the EPA Regional Administrator and

EQB within 30 days, per Puerto Rico regulations, after the waste was accepted by the initial transporter

(off-installation).

The EM is responsible for maintaining a HW file. The file contains waste stream analyses or waste stream profile records including Safety Data Sheets (SDS); Defense Turn-in Document (DTID), if DLA-DS is used; HW contract documents; manifests; letters of authority for funds certification and manifest certification; HW training schedules and installation records of HW training; HW accumulation site weekly inspection forms; installation waste stream inventory; an updated HWMP; and a copy of the documentation relevant to preparedness and prevention and emergency response for the installation.

The EM reviews plans to build, site, purchase, modify, or relocate HW CAPs or SAPs. In addition, he/she conducts weekly inspections of the HW CAP (See Section 5.4).

The EM reviews the HWPS prepared by waste-generating activities for accuracy. The HWPSs are maintained in a file by the EMO.

The EM is responsible for performing duties as assigned by the installation commander. Duties may include signing manifests, if designated, assisting shops with HW management duties, managing the CAP, waste stream characterization, packaging and labeling HW containers, providing HW training, and similar duties.

The EM assists generating activities in determining the proper shipping name required by United States

Department of Transportation (DOT), the proper DOT hazard class, and the DOT required label. The EM is also responsible for processing paperwork transactions of any services procured and maintaining computer records of HW disposal action by DLA-DS when applicable. Transactions will be processed to

156th Airlift Wing Puerto Rico Air National Guard Page 14 record turn-in actions to DLA-DS or independent contractor. DLA-DS disposal documentation will be produced when disposal by DLA-DS is required and has been authorized by the EM.

State Environmental Officer

The EM has the ability to designate responsibilities (noted above as EM responsibilities) to the SEO as needed.

2.2.4 Civil Engineering Squadron

CES maintains base facilities, including those that are used as accumulation sites, and will also facilitate in providing personnel and equipment for spill response.

Fire Department

The Installation Fire Chief or designee is responsible for instructing the generating activities on the correct

National Fire Protection Association (NFPA) codes to show at their respective accumulation sites. A Fire

Department representative(s) must be present when a container of unknown material/waste is opened.