Appendix J - Overseas Hazardous Waste Management Plan.pdf

U.S. AIR FORCE

Overseas Hazardous Waste Management Plan

Pituffik Space Base

Peterson - Pituffik SB

About This Plan

Document Control

HWMP Approval (Signature Page)

1 Overview and Scope

2 Installation Profile

3 Environmental Management System

4 Roles and Responsibilities

5 Training

6 Recordkeeping and Reporting

7 Procedures

7.1 Waste Inventory

7.2 Waste Identification

7.3 Container Management

7.4 Labeling and Marking

7.5 Hazardous Waste 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 References

9 Acronyms

10 Definitions

11 Installation-Specific Content

Appendix A Waste Analysis Plan

ABOUT THIS PLAN

This installation-specific Environmental Management Plan (EMP) uses the U.S. Air Force’s (AF) standardized Hazardous Waste Management Plan (HWMP) template for overseas installations. This plan is not an inventory of all hazardous waste (HW) requirements and practices. External resources, including Air Force Instructions (AFIs); Air Force Manuals (AFMANs); AF Playbooks; Final Governing Standards (FGS); and permit requirements, are referenced.

Each section of this plan begins with standard language that addresses AF and Department of Defense (DoD) policy and federal requirements. The standard language is restricted from editing to ensure consistent application across the AF enterprise. Standard language is maintained by the Air Force Civil Engineer Center (AFCEC) designated Subject Matter Expert (SME) for this plan.

Immediately following the standard text are installation-specific sections that address country, local, and installation-specific requirements and processes. Installation sections are maintained and updated by the installation HW Program Manager and/or the AFCEC Branch and/or Air Force Installations and Mission Support Center (AFIMSC) Detachment appointed to support this installation.

This document is optimized to be accessed and viewed electronically on the installation and AF eDASH website, the primary communication tool for AF EMPs.

DOCUMENT CONTROL

Standardized HWMP Template

In accordance with (IAW) the AFCEC Environmental (CZ) Business Rule (BR) 08, EMP Review, Update, and Maintenance, the standard content in this HWMP template is reviewed periodically, updated as appropriate, and approved by the HW and Environmental Overseas

SME.

This version of the template is current as of 06/05/2020 and supersedes the 2018 version.

NOTE: Installations are not required to update their HWMPs every time this template is updated. When it is time for installations to update their HWMPs, installations should adopt the most recent version of this template available.

Installation HWMP

The initial HWMP must be approved and signed by the Installation Commander (at the time of publication) as the legal HW Generator for this installation. The approval can be via signature or as documented in appropriate Environment, Safety, and Occupational Health Council (ESOHC) minutes (AFMAN 32-7002, 3.2.2.). NOTE: This is not a Wing Contingency Plan and is not governed by installation or Wing plans or readiness format or coordination requirements of AFI 10-401, Air Force Operations Planning and Execution. It is governed by AFMAN 32-7002, Environmental Compliance and Pollution Prevention, Section 5.2. Hazardous Waste Management Plan (HWMP). Because this is not a contingency plan, coordination should be with Environmental Management System Cross Functional Team (EMS CFT) and applicable units with roles and responsibilities in the HWMP. The plan does not require a new signature after each change in wing command.

Record of Updates – The HWMP is updated as changes to waste generation and management practices occur, including those driven by changes in applicable regulations and approved by the installation HW Program Manager as the plan Office of Primary Responsibility (OPR). Formatting and administrative changes such as the incorporation of updated regulatory language, or other minor updates are documented below.

Record of Annual Review – IAW AFMAN 32-7002, this plan is reviewed annually by the EMS CFT. Formatting and administrative changes should be noted in the previous paragraph for record of updates as approved by the EMS CFT Chair and do not require Installation Commander or Environmental, Safety, and Occupational Health Council (ESOHC) approval. Substantive revisions require coordination and approval by the Installation Commander as determined by the EMS CFT Chair and/or IAW host installation procedures. Substantive changes include manpower or resource requirements changes that impact installation hazardous waste generating organizations.

Record of Updates

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

Initial Initial version using the new

Overseas HWMP template Reviewed by AFCEC, 21 CES/CEIE and EMS CFT

29 November 2022 Col Capps 16 Dec 2022

Record of EMS CFT Annual Review

Review Date Review Participants Notes/Remarks Result in Plan Update?

(Yes or No)

20 January 2023 VS ESH

21 CES/CEIE

EMS CFT (24 Feb 2023)

No changes since the template update

No

20 July 2023 Peterson ESOHC Approval No

HWMP APPROVAL (SIGNATURE PAGE)

1 OVERVIEW AND SCOPE

This HWMP contains procedures for management of HW to implement the FGS requirements, or if no FGS exists, the Overseas Environmental Baseline Guidance Document (OEBGD). AFMAN 32-7002 acts as a main driver for the HWMP. Also the HWMP addresses special requirements of DoDI 4715.05, Environmental Compliance at Installations Outside the United States, for the disposal of HW in host-countries. The HW Playbook serves as supplemental guidance to this plan.

The scope of the Hazardous Waste Management Plan is to ensure documented guidance for HW management is available to all installation personnel. Thule follows the Final Governing Standards (FGS-GL 2020).

The documentation will include:

Identification of all HW generators Identification of all HW streams Identification and description of all HW produced Procedures for handling, storing, and disposing of HW Monitoring the required HW management procedures as described in this plan Continued evaluation and update of the HW inventory and analysis plan

2 INSTALLATION PROFILE

Installation Profile

Scope of Plan Thule Air Base

OPR

(Civil Engineer or designated office that has overall responsibility for implementing the HW management program and is the lead organization for monitoring compliance with regulations.)

VS/ESH Department

HW Program Manager VS/ESH Supervisor Alternate HW Program Manager VS/ESH Specialist Emergency contacts Fire Department Waste registration numbers Thule obtains a temporary EPA ID from Virginia Department of

Environmental Quality (VDEQ) annually FGS (or OEBGD) regulatory references FGS-GL 2020 Approved HW disposal contractors Defense Logistics Agency (DLA) HW storage areas Bldg. 935 and Bld. 604 HW accumulation time limits 1 year HW generator reporting frequency Annually

3 ENVIRONMENTAL MANAGEMENT SYSTEM

The AF environmental program adheres to the EMS framework and its Plan, Do, Check, Act cycle for ensuring mission success. Executive Order (EO) 13834, Efficient Federal Operations, U.S. Department of Defense Instruction (DoDI) 4715.17, Environmental Management Systems, AFI 32-7001, Environmental Management, and International Organization for Standardization (ISO) 14001, Environmental management systems - Requirements with guidance for use, 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 manage associated risks, and instill a culture of continuous improvement. The HWMP serves as an administrative operational control that defines compliance-related activities and processes.

4 ROLES AND RESPONSIBILITIES

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

Wing/Installation Commander

ESOHC

EMS CFT

HW Program Manager/Alternate Shop/HW Generator Personnel Hazardous Waste Accumulation Point (HWAP) and Hazardous Waste Storage Area (HWSA) Supervisors/Managers Unit Commanders Unit Environmental Coordinators (UECs), see AFI 32-7001 for role description Contracting Officer Defense Logistics Agency Disposition Services (DLA-DS) Tenant Organizations

AFCEC

AFIMSC Detachment

Detailed information about typical responsibilities for these and other roles is available in AFMAN 32-7002, applicable installation supplements, and the HW Playbook. Additional HW management-related roles and responsibilities are described throughout this plan and in referenced documents.

VS/ESH is the office of primary responsibility for developing and maintaining the Hazardous Waste Management Plan. The instructions given in this plan are applicable to all organizations and tenant units at Thule AB. Organizations are authorized to extract and reproduce those sections of the plan essential in the accomplishment of necessary planning and in the preparation of supporting documents and reports.

5 TRAINING

5.1. Hazardous waste awareness training is provided to satisfy AFMAN 32-7002 and country-specific FGS requirements and needs. All training requirements and sources are provided in the Environmental Training Matrix on eDASH. Specific local training procedures are provided in section 5.5.

5.2. Hazardous waste training is provided only by qualified authorized personnel. Training records are maintained IAW the Recordkeeping and Reporting section of this plan.

5.3. Hazardous waste program managers and alternates appointed in writing by the Wing Commander to sign manifests, require specific training to include HW Management Compliance Training and Department of Transportation training to sign HW manifests.

Installation HW Program Managers should complete the Air Force Institute of Technology in-residence course (or equivalent) AFIT 521, Hazardous Waste Management. After initial course completion, refresher training is required annually for RCRA. See training matrix for more information.

5.4. Function-Specific Training (Local In-House/On-Line Training Sources): (Group A) Organizational (non-central) Hazardous Waste Storage Area Managers, HW Accumulation Point Managers, and their immediate supervisor; and (Group B) all shop personnel, and their immediate supervisors, who generate HW.

5.5 Each installation should make a determination of the applicable host-nation transportation regulations to determine the degree of training required for those preparing hazardous materials, consisting of hazardous waste on a manifest for ground transportation on public roads. Installations will enter procedures below regarding site-specific training requirements below based upon FGS and Host Nation (HN) regulations, consistent with the eDASH training matrix.

The Hazardous Waste Handler Course is mandatory for personnel that handle or otherwise manage HW, and their supervisor/superintendent/manager. Supervisors/superintendents/managers will participate a minimum of one time, while personnel who handle hazardous waste (e.g. POCs for HWAP) will participate once per year.

Newly assigned personnel handling HW should be provided the training before starting the job. The training can be accomplished by completing a Danish language e-learning module developed by the VS/ESH.

The training is developed and conducted IAW FGS C6.3.9 and FGS C6.3.9.3 and includes:

Chemical hazards of HW Regulatory overview Emergency procedures (response to spills, spill kits, cleanup, etc.)

Drum/container handling/storage and safe use of HW equipment Personal protective equipment Record keeping, inspections, contingency plans and storage requirements Turn-in procedures (HW profiles, funding documents, etc.)

6 RECORDKEEPING AND REPORTING

Recordkeeping

The installation complies with the following HW recordkeeping requirements, as applicable, based on generator status. Records may be kept in either paper or electronic form. While the OEBGD has a baseline requirement of 3 years, each installation must be familiar with unique FGS requirements and include appropriate details in their installation supplement section.

Reporting

The HW Program Manager, and other designated personnel, generate needed reports from the Enterprise Environmental, Safety, and Occupational Health - Management Information System (EESOH-MIS).

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

HW must be tracked in EESOH-MIS within three days of receipt at HWSA.

Summary of HW Recordkeeping Requirements

Record Retention Time* Citation HW determination documentation 3 years from the closure of the HWSA and

HWAP

FGS/OEBGD

HW manifest (turn-in document) 3 years FGS/OEBGD HWSA logs (inspection, container and/or inventory records, etc.)

Until closure of installation FGS/OEBGD

HW inspection logs 3 years FGS/OEBGD Employee HW training records 3 years from date of termination of duties FGS/OEBGD PCB Items 3 years after disposal of the last item FGS

* 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. Note that the records required by law, external regulation, or OEBDG/FGS should be readily available on-site. Records required by AF Record Retention requirements can be archived.

7 PROCEDURES

This section contains procedures for managing HW from identification, accumulation, offsite transportation and disposal. The HW Program 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, and select “Hazardous Waste” to generate the Waste Site Waste Stream Summary Report.

HW inventory is based on the information provided by each individual shop at Thule AB, and contains federal hazardous waste generated on a recurring basis at the shop level. When a new waste stream is generated the shop must report to the VS/ESH who will enter the stream into the EESOH-MIS system. The shop can call VS/ESH and get a copy of the hazardous waste streams.

List of recurring industrial generated hazardous waste streams* Type of Waste Waste Stream Code Sources

(Unless otherwise indicated) HW characteristics

Rags with Solvent HWAP-02 Vehicle Maintenance 1412 Facility Maintenance 1413 Facility Maintenance 801 M-Plant 1391 J-Plant 4016

F003

Fuel contaminated Adsorbent HWAP-03 Basewide D001 Aerosol Spray Residue (except paint) HWAP-04 935 D001 Batteries, Misc. HWAP-05 Basewide D002, D006, D008 Fluorescent Light Bulbs HWAP-06 Basewide D009 Paint (oil-based) HWAP-07 Facility Maintenance 801 D001 Paint related material (Thinner) HWAP-09 Vehicle Maintenance 1412

Facility Maintenance 801 D001

Aerosol filter (paint can puncture) HWAP-10 935 D001 Used oil filters vehicle HWAP-11 Vehicle Maintenance 1412

Airport Ground Equip 1408 D001

Used fuel filters, vehicle HWAP-12 Vehicle Maintenance 1412 D001 Drained fuel filters, fuel operations HWAP-13 K-Plant 1401 D001 Drained oil filters, power production HWAP-14 J-Plant 4016 D001 Old Mercury Switches HWAP-19 Facility Maintenance 1413 D009 Dry Cleaning Sludge HWAP-20 Laundry Services 237 D001 Lead Solder HWAP-21 Non-Secure Comm. 1411 D008 Aerosol Spray Residue - Paint HWAP-22 Base wide D001 Paint booth filters HWAP-24 Vehicle Maintenance 1412 D005, D007, D008, D010 Aerosol cans HWAP-26 Base wide D003 Filter, florescent light bulb crusher HWAP-27 935 D009 Locktite hardener HWAP-30 Base wide D002 Amacoat resin 78 HWAP-31 Base wide D002 Washing detergent HWAP-37 Base wide D002 Degreaser HWAP-40 Base wide D002 Paint HWAP-46 Base wide D001 Paint related material HWAP-50 Base wide D001 Dishwashing liquid HWAP-56 Base wide D002 Flameless ration heater HWAP-57 Base wide D003 Flammable Solid (gasoline ) HWAP-59 Base wide D001 Rags with JP8 HWAP-61 Base wide D001

*Waste streams disposed of by DLADS characterized as HAZMAT without USEPA waste codes are reported in EESOH-MIS, but not included in this table.

Waste from different sources that is part of the same waste stream may be mixed prior to disposal. When DLADS is listed as disposal method, the waste is annually shipped to Norfolk, Virginia as HW.

7.2 Waste Identification

The HW Program 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 Program Manager pursues waste stream sampling and analysis IAW the Waste Analysis Plan (WAP) found in Appendix A.

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.

7.2.1. Characteristics of Hazardous Waste

There are four HW characteristics. If a waste exhibits one or more of the four characteristics it is a HW. Characteristics can be determined by the user's basic knowledge, SDS, or by analyzing the waste.

Ignitable Waste (D001)

A solid waste exhibits the characteristic of ignitability if a representative sample of the waste has any of the following properties:

It is a liquid, other than an aqueous solution containing less than 24 percent alcohol by volume and has a flash point less than 60°C (140°F).

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

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

It is an oxidizer.

For example, oil-based paint, cleaners, solvents, and contaminated fuel.

Corrosive Waste (D002) Waste is corrosive if:

It has a pH-value of less than 2.

It has a pH-value of greater than 12.5.

It is a liquid and corrodes steel.

For example, strong acids such as battery acid and hydrochloric acid, bases such as sodium hydroxide.

Reactive Waste (D003) Waste is reactive if it is an unstable material that can pose a problem at any stage of the waste management cycle. A solid waste exhibits the characteristic of reactivity if a representative sample of the waste has any of the following properties:

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

It reacts violently with water.

It forms potentially explosive mixtures with water.

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

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

It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement.

It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.

It is a forbidden explosive.

For example, cyanide, UXO and flares.

Toxicity Characteristic Waste (D004-D043)

Waste has a toxicity characteristic if it contains one or more compounds in a concentration equal or higher than the regulatory level listed in the FGS Table AP1.T1 and AP1.T2 and for reference only please refer to 40 CFR Section 261.24 for the most current list.

7.2.2. Listed Hazardous Waste

A listed HW is a waste identified on one of four lists published in the USEPA regulations. The following are present at Thule AB:

F-listed waste at Thule AB only applies to waste generated from the use of certain common organic solvents. Solvents used for their solvent properties, for example - used for degreasing and cleaning. The listing only covers solvents that are above a certain concentration before use. Only F002 and F003 are found in recurring waste streams at Thule AB.

(Rags used for cleaning or degreasing and waste residue)

7.2.3 Hazardous Waste Mixtures

A HW mixture is a mixture of a listed HW and any other material, or a mixture of a characteristic HW and any other material - provided that the mixture still exhibits the hazard characteristic. Most mixtures of HW and other wastes or materials are classified as HW.

Therefore, mixing a HW with a non-HW does not produce a non-hazardous mixture.

7.2.4 Hazardous Waste Residue

Any residue remaining in a container, or an inner liner removed from a container that held any commercial chemical product or manufactured chemical intermediate, having the generic name listed in the FGS Table AP1.T4, annotated "F", "P" or "U" as the first character in the USEPA waste number.

Any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill into or on any land or water of any commercial chemical product or manufactured chemical intermediate having the generic name listed in the FGS Table AP1.T4, annotated "F", "P" or "U" as the first character in the USEPA waste number.

When disposing of used empty containers the following requirements will be followed:

Containers that have previously held non-HM can be disposed of as solid waste.

A container that has previously held an acute HM, as defined in the FGS, is considered "empty", only if it has been triple-rinsed with an appropriate solvent, or the liner has been removed. The manufacturer's SDS will be examined to determine if the material contains acute hazardous components.

7.2.5 Lead-Based Paint

Hazardous waste includes lead-based paint.

VS/ESH has reports on file for building materials with lead-based paint IAW the FGS requirement to characterize and determine if waste streams are hazardous.

Construction debris containing lead-based paint from building demolition does not meet the criteria of hazardous waste characterization.

7.2.6 Polychlorinated Biphenyls

Installations that generate PCB waste of 50 ppm or greater will maintain an audit trail for the wastes.

The PCB wastes of 50 ppm or greater will be retrograded for disposal outside of Greenland as hazardous waste IAW FGS C14.3.5.

7.3 Container Management

Container management procedures are as follows:

Containers storing HW must be in good condition and meet 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.

Segregate and store incompatible wastes separately.

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. The required headspace is unique to each waste stream and expected storage conditions. For liquids and volatile chemicals, a general rule is to not fill to more than 85% of container capacity to allow for temperature changes, and that equates to approximately four inches of headspace in a typical 55-gallon drum. The ultimate requirement is performance based, such that drums do not bulge or leak. A good inspection process will enable any recommendations for specific waste streams as appropriate.

Containers holding HW must not be opened, handled, or stored in a manner which may rupture the container or cause it to leak.

Containers of flammable liquids must be grounded when transferring flammable liquids from one container to the other.

HWAPs and HWSAs with containers must have a secondary containment system that meets the following requirements

1. Must be sufficiently impervious to contain leaks, spills, and accumulated precipitation until the collected material is detected and removed;

2. The secondary containment system must have sufficient capacity to contain 10 percent of the volume of stored containers or the volume of the largest container, whichever is greater.

A container holding HW must always be closed during storage, except when it is necessary to add or remove waste.

A container holding HW must not be opened, handled, or stored in a manner which may rupture the container or cause it to leak.

Containers of flammable liquids must be grounded when transferring flammable liquids from 1 container to the other.

Containers holding HW will be marked with a HW marking, and a label indicating the hazard class of the waste contained (flammable, corrosive, etc.).

Areas where containers are stored must be inspected weekly for leaking and deteriorating containers as well as deterioration of the containment system caused by corrosion or other factors. Secondary containment systems will be inspected for defects and emptied of accumulated releases or retained storm water.

7.4 Labeling and Marking

Containers used for the accumulation and transportation of HW must be properly identified with a HW marker and an appropriate hazard class label (e.g., flammable, corrosive, etc.) at all times from the start of accumulation to ultimate disposal IAW applicable laws and regulations. The HW marker for transportation will include a description of the contents of the container in the form of a Proper Shipping Name (PSN) as established in the waste characterization process and used on the waste manifest which accompanies the container to the ultimate disposal site (either paper or approved electronic form).

When transporting HW via commercial transportation on public roads and highways, HW generators will prepare off-installation HW shipments in compliance with DoD Component Policies. Requirements may include placarding, marking, containerization, and labeling.

HW designated for international transport will be prepared in accordance with the documents listed above and applicable international regulations.

EESOH-MIS, HW Module has a version of the HW label that can be customized (i.e., HN language) and utilized.

Containers will be properly marked to indicate their use for waste accumulation.

The container will be marked with one of the three labels.

All other markings on the container from previous use will be removed before waste accumulation.

7.4.1 Hazardous Waste Label

Yellow label: "HAZARDOUS WASTE" is used when the waste is determined to be hazardous. The information on the label will include:

Name: Organization (e.g. 821ABG/VS/SVCS, Bldg. #237)

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

US-EPA id no.: e.g. MIR 0000 36616

EPA waste no.: The EPA waste no. (stated by MSDS/SDS, or FGS, e.g. D001)

Accumulation start date: The date the drum is filled to 90% of its capacity

The proper shipping name and UN number will be written e.g. "Environmentally Hazardous Substances Solid N.O.S" UN: 3077.

White label: "THIS CONTAINER ON HOLD PENDING ANALYSIS" is used if the content of the container is unknown and awaits analysis results on HW characterization. The information on the label will include:

Contents: e.g. Drum found on base

Origin of materials: Process or activity, e.g. Drum Project

Address: Organization (e.g. 821ABG/VS/OMEP, Bldg. #801)

Accumulation start date: Date of sampling

Black label: "USED BATTERIES" is used for batteries.

Shipper: Organization (e.g. 821ABG/VS/CEMR, Bldg. #1413)

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

Contents: Used batteries/ hazardous waste

7.4.2 Non Hazardous Waste Label

Green label: "NON-HAZARDOUS WASTE" is used when the waste is determined to be non-hazardous. The information on the label will include:

Shipper: Organization (e.g. 821ABG/VS/SV, Bldg. #237)

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

Contents: e.g. used developer

"Used oil" label is used for oil suitable for energy recovery - see Solid Waste Management Plan (SWMP). The information on the label will include:

Company: Organization (e.g. 821ABG/VS/LGTM, bldg. #580)

Address: Thule Air Base, Greenland

City: APO AE 09704-5000

Source: e.g. Oil changes in VM

Contact: Hazmat specialist, Shop Supervisor or waste oil truck

"Drained used oil filter" label is used for oil filters. The information on the label will include:

Accumulation start date: The date the drum is filled to 90% of its capacity. Below the "Accumulation start date" write shop name (e.g. VS/LGTM bldg. #1412)

7.5 Hazardous Waste Management

An HWAP may be used to accumulate no more than 208 liters (55 gallons) of HW, or 1 liter (1 quart) of acute HW, from each waste stream. When these limits have been reached, the generator will make arrangements within five working days to move the HW to an HWSA or ship it off-site for treatment or disposal.

Hazardous waste should be stored IAW OEBGD or FGS requirements (i.e. not stored longer than 90 days, 180 days, one year) in an

HWSA.

Wastes intended to be recycled or used for energy recovery (e.g., used oil or antifreeze) are exempt from the 208-liter (55-gallons)/1-liter (1-quart) volume accumulation limits, but must be transported off-site to a final destination facility within one year.

Thule AB has two types of HW accumulation and storage points:

HWAP - Hazardous Waste Accumulation Point, IAW FGS C6.2.6 and FGS C6.3.2 HWSA - Hazardous Waste Storage Area, IAW FGS C6.2.10 and FGS 6.3.3

All HW will be accumulated in approved accumulation and storage points.

7.5.1 Hazardous Waste Accumulation Point (HWAP)

HWAPs are located within the following buildings:

Bldg. 237, 801, 935, 1391, 1401, 1408, 1411, 1412, 1413, 4002, 4016.

The requirements for a HWAP are as follows:

In the event new HW streams are identified, HWAPs will be established or the waste stream will be added to an existing HWAP in coordination with VS/ESH.

At Thule AB, HWAPs may be used to accumulate non-hazardous wastes unacceptable for landfill disposal IAW A071 Solid Waste Management Plan. This includes non-regulated wastes such as used glycol and e-waste as well as regulated waste that does not meet the definition of hazardous waste (e.g. PCB items such as ballasts).

Documentation for HWAPs is located at DLADS (turn-in documents, manifests) and VS/ESH (waste analysis records).

An HWAP is an area designated for the accumulation of HW at or near the point of generation. The requirements for the HWAP will ensure the waste is accumulated in a proper and environmentally sound manner.

HW that contains free liquids will be placed in secondary containment. The secondary containment will have sufficient capacity to contain 10% of the volume of all containers, or the volume of the largest container, whichever is greater.

Each HWAP will be designed and operated to provide appropriate segregation for different waste streams, including those, which are chemically incompatible.

The HWAP will be segregated from all potential ignition sources, including electrical sources, open flames, heat sources, cutting and welding operations, any smoking areas and ashtrays at a distance of 50 ft.

When the container is 90% filled, the container will be transferred to a HWSA within five working days.

Containers will be UN-approved except for containers for batteries.

Containers will be in a good condition (no rusting, bulging or structural defects).

A container holding hazardous waste must be closed during storage, Containers with flammable liquids will be grounded.

Appropriate spill absorbent for the waste stored will be available.

Personal protective equipment will be available in sufficient amounts and appropriate for the waste stored (e.g. an eyewash station).

The HWAP will be orderly and not contain items or materials that are not intended for disposal or recycling via DLADS within the designated area.

Personal training requirements will be met. It is the responsibility of the shop supervisor to only assign personnel to HWAP duties after they have received hazardous waste training. Documentation for completed training for BMC personnel is available at BMC Administration section.

Each shop will inspect the HWAP at least once every quarter as part of a self-inspection based on the requirements mentioned above.

Wastes intended to be recycled or used for energy recovery (for example, used oil or antifreeze) are exempt from the 208-liter (55-gallons)/1-liter (1-Quart) volume accumulation limits, but must be transported off-site to a final destination facility within 1 year.

7.5.2 Hazardous Waste Storage Area (HWSA)

A HWSA is an area designated for accumulation and storage of HW.

Thule AB has the following HWSAs:

Bldg. 935 – Consolidation of HW, waste under management. Operated by BMC DLADS.

Only for storage of HW:

Bldg. 604 operated by BMC DLADS.

Thule AB HWSA's are located inside locked buildings, with restricted access IAW FGS C6.3.3.4.1.

The requirements for a HWSA are as follows:

HW that contains liquids will be placed in secondary containment.

The HWSA will be designed and maintained to prevent fire, explosions, and release of HW/HM into the environment.

A sign will be posted and will be visible from at least 25 feet from all approaches. The sign will have the following text:

English:

"DANGER UNAUTHORIZED PERSONNEL KEEP OUT"

"HAZARDOUS WASTE MANAGEMENT AREA"

Danish:

"Uvedkommende ingen adgang" "Område med farligt affald"

Greenlandic:

"Navianartoq susassaqanngitsut iseqqusaanngillat" "Tamanna nakkutigineqarpoq Navianartumik ilitsivik

Ignitable or reactive waste will be segregated from all potential ignition sources to prevent fire or explosions. These types of waste will be separated from all electrical sources, heat sources, open flames, cutting or welding operations, and smoking areas at a distance of 50 ft.

Incompatible wastes will be properly segregated.

Personal protective equipment will be available in sufficient amounts and appropriate for the waste stored.

A Closure Plan for each existing HWSA is available.

The BMC DLADS will prepare the manifest for all off-site shipments and maintain a copy of the manifests for at least three years after shipment.

When stored in Bldg. 604, the containers will be placed on pallets and sufficient aisle space will be ensured between rows to allow forklift operation and ready access for inspection and possible leak response. Bldg. 604 is not heated.

Persons handling HW must have immediate access to commutations. This is accomplished as all personnel working handling HW carry a TETRA-radio.

Aisle space will be wide enough to allow inspection of the drums. A minimum of 4 ft. is recommended along the center aisle, and a 2 ft. vertical and horizontal aisle should be provided between the other rows.

The HWSA will be inspected weekly IAW FGS C6.3.3.8.1 (see section 7.8).

Portable fire extinguishers, spill control equipment and decontamination equipment will be available.

7.5.3 Closure Plans

Every HWSA will have a closure plan before it is opened. The plan will specify the procedures to be followed in order to achieve complete and safe closure. See section 11.7 for requirements to the closure plan. A Closure Plan for the two existing HWSA is available at VE/ESH.

7.6 Transportation

The HW Program Manager has overall responsibility for the transportation of HW from an HWAP to a HWSA, and from an HWSA to the disposal facility. The HW Program Manager ensures:

All transportation over HN public roads is conducted IAW applicable HN or international transportation regulations.

Containers are approved.

Transporters have the appropriate training.

Uniform HW Manifests are prepared for offsite transportation, and signed by a duly authorized signatory.

All necessary documentation has been completed and records are maintained IAW all applicable requirements and the AF Records Disposition Schedule.

No public roads are located at Thule. All roads are located on the installation. Hazardous waste gets shipped out once per year by ship to Norfolk, Virginia.

Shortly (7 to 8 days) before the Pacer Goose departs from Thule AB to Norfolk, VA, USEPA Form 8700-12 "RCRA Subtitle C Site Identification" is prepared for 821 ABG/CC signature. Consequently, the signed form is submitted to the Virginia Department of Environmental Quality (A069 Hazardous Waste Permit). The USEPA Provisional ID Number will be renewed after 30 days of the initial number, if the HW has not reached its final location.

7.7 Turn In/Disposal

The turn in procedures contained in DoD 4160.12-M. DLA Disposition Services must be followed. In the event an alternate disposal agent is needed, a waiver will be obtained with proper justification and approval.

Containers are inspected prior to turn-in to ensure that container management procedures have been followed and that containers are properly labeled and in good condition. If the container is not in good condition, contents must be transferred to a container that is in good condition.

In addition to the FGS or OEBGD (where no FGS has been issued), or similar directive, the management and disposal of hazardous wastes outside the United States associated with applicable military activities will comply with these additional procedures prescribed by DoDI 4715.05 for the disposal of hazardous wastes.

7.7.1 Hazardous Waste Turn-in Procedure

The following procedures will be followed when HW is turned in (see schematic below):

Waste generator:

For current waste streams, turn-in HW when container is 90% full Solids HW do not require any further packing. Make sure lids are securely fastened before transport to DLADS.

IBC container with glycol and used oil do not require any further packing.

For no current waste streams, provide SDS or analysis results. Turn-in HW in original container if possible.

Contact the DLADS, ext. 3737/2808, before turn-in stating:

HW stream Container size and labeling Location (bldg.)

HW is turned in at bldg. 935.

BMC DLADS:

Receive HW from generators.

Liquid in 55-gallon drums or smaller are over packed.

Provide new container with label and markings upon request from generator.

The DLADS will, in cooperation with VS/ESH, fill out the turn-in papers for HW in EESOH-MIS. HW storage and turn-in is tracked through EESOH-MIS database.

The BMC DLADS will, in cooperation with VS/ESH, provide SDS or HW analysis.

All HW turn-in documents will be kept on file for a period of three years from the date of turn-in.

7.7.2 Hazardous Materials Turn-in Procedure

The procedure for turn in of HM, only batteries, is the same as for HW, except for the following:

The original price or an estimate price will be used.

The strict regulations, which apply for packaging HW, do not apply for HM, but packaging will be appropriate for transportation.

7.8 Inspection

Inspection processes fulfill the “Check” function of the EMS “Plan, Do, Check, Act” cycle. Hazardous Waste Storage Areas (HWSA) are inspected routinely IAW the FGS to ensure proper accumulation and container management. All other inspections occur IAW AFI 90- 201, The Air Force Inspection System, and the Commander’s Self Inspection Program. Inspection records are maintained IAW the Recordkeeping and Reporting section of this plan.

Each shop will inspect the HWAP at least once every quarter as part of a self-inspection based on the requirements in a checklist. Areas where containers holding HW are stored are inspected weekly.

The HWSA's are inspected IAW FGS C6.3.3.8.1 for malfunctions and deterioration, operator errors, and discharge that may be causing, or may lead to, a release of HW constituents to the environment or threat to human health. HWSA where containers are stored are inspected weekly IAW FGS C6.3.4.1.5., and annually by Fire Protection.

Inspection are conducted according to a written schedule kept in the HWSA IAW FGS C6.3.3.8.3 and records of inspections maintained for 3 years IAW FGS C6.3.3.5.4.

7.9 Waste Minimization

Hazardous waste manifests include certification that a waste minimization program is in place. Below are key activities and processes that are performed as part of waste minimization and pollution prevention efforts:

Hazardous material process authorization and hazardous materials management processes – Each process involving use of hazardous materials and generation of waste streams is evaluated and authorized. Process authorization is performed through EESOH-MIS. The HW Program Manager, Hazardous Materials Management Program (HMMP) Team, and the generating activity make a final determination whether or not the results of the process authorization effort are sufficient to reduce waste toxicity and volume.

Procurement and use of minimal quantities – When a material with environmental risk must be used, minimal quantities are procured to minimize surplus quantities and shelf life exceedances.

Recycling – When the use of hazardous materials is unavoidable, excess or waste material is evaluated for reuse or recycling options.

Environmental action planning – Environmental action plans (EAPs) are developed and maintained as part of the overall EMS.

Environmental action plans are management plans that translate environmental objectives and targets into actionable plans.

Waste minimization efforts are considered during development of EAPs.

Objectives are to:

Minimize the amounts of generated hazardous waste through wise thinking Achieve a full state of awareness throughout the installation in order to protect employee health from hazardous waste.

Provide a safe work environment.

Minimize adverse effects on the environment from the generation and disposal of HW.

Minimize the disposal costs of the generated HW.

7.10 Preparedness and Prevention

Preparedness and prevention practices are described in emergency prevention and response plans available through the references section of this plan and are maintained IAW the EMS on eDASH: Emergency Preparedness and Response, and shall include as warranted the Installation Spill Prevention and Response Plan (or equivalent) or a specific HW Contingency Plan.

SPILL CONTINGENCY PLAN

HAZARDOUS WASTE ACCUMULATION POINT

IF A SPILL OCCURS IN THIS BUILDING, AND HUMAN LIFE COULD BE THREATHENED DUE TO OIL OR CHEMICALS, THE BUILDING SHOULD BE EVACUATED IMMEDIATELY THROUGH THE EVACUATION ROUTE, WHICH IS LOCATED ON THE DRAWING WITH A RED

COLOR.

IF A SPILL OCCURS IN THIS BUILDING THEN NOTIFY THE FIRE DEPARTMENT, 911

WHEN NOTIFYING THE FIRE DEPARTMENT THE FOLLOWING INFORMATION SHOULD BE PROVIDED:

1. NAME OF INDIVIDUAL REPORTING SPILL.

2. LOCATION OF SPILL.

3. NUMBER OF INJURED PERSONNEL.

4. SUBSTANCE SPILLED.

5. AMOUNT OF SPILLED SUBSTANCE.

6. RATE AT WHICH SUBSTANCE IS LEAKING AND SOURCE.

7. TIME SPILL OCCURRED.

THE FIRE DEPARTMENT WILL BE RESPONSIBLE FOR ANY FURTHER ACTION TO BE TAKEN.

PRECAUTIONS DURING DIRECT CONTACT

WITH HEALTH HAZARD COMMODITIES:

The only situations you stay within range of a spill are:

To help another person to evacuate the area, if you can do so without endangering yourself

To prevent contamination by placing absorbing mats or spill-booms around the spill

To turn a leaking container, if possible without endangering yourself, so the leak is up to avoid further spillage

To protect yourself use the following guidelines:

Familiarize yourself with the properties of the hazardous waste/material handled and type of injuries or illness that could result from emergency situations.

The information can be obtained through the SDS, located in the SDS binder.

Avoid skin contact with the chemicals. Wear appropriate protective clothing, such as rubber boots, overalls rubber or plastic aprons, and rubber gloves, when staying near any spill whether the chemical is liquid, powder, or crystalline.

Avoid breathing vapors, dust, or gases produced by any chemical spill. Wear the appropriate respirator, when staying in the area of a spill.

With dust, powder, crystalline spills, keep the area closed (reduce ventilation) to avoid airborne spread.

Outdoors, keep the wind in the back at all times, to avoid blowing powder and vapor.

Contaminated areas will not be cleaned up or washed down until Environment Safety and Health (ESH) personnel has arrived and evaluated the effect of the contaminated waste waters which would be produced by wash down operations. After the ESH's evaluation it is decided who will clean up the area. For contaminating spill this is done by the Spill Response Team.

7.11 Waste Specific Procedures

Waste-specific procedures are included in the installation supplement below or maintained as separate operational controls outside of this plan.

N/A

8 REFERENCES

Standard References (Applicable to all AF Installations)

AFI 32-7001, Environmental Management AFMAN 32-7002, Environmental Compliance and Pollution Prevention AFI 90-201, The Air Force Inspection System AFLOA HW Legal and Other Requirements – The Air Force Legal Operations Agency (AFLOA) legal registry lists and provides access to FGSs, DoD, AF, and other legal requirements DoD 4160.21 (all volumes), Defense Materiel Disposition EASIER Database eDASH HW Environmental Action Plans (EAPs) eDASH HW Home Page eDASH HW Training Matrix EESOH-MIS Application Login EESOH-MIS Support Portal The Environmental Awareness Course Hub (TEACH) HW Playbook Final Governing Standards (FGS) – Greenland (GL) 2020 Performance Work Statement (PWS) Thule Base Maintenance Contract (BMC) FA2523-15-C-001

9 ACRONYMS

Standard Acronyms (Applicable to all AF Installations) eDASH Acronym Library HW Playbook – Acronym Section BMC – Base Maintenance Contract DLADS – Defense Logistics Agency Disposition Services.

FGS-GL – Final Governing Standards for Greenland HM – Hazardous Material HW – Hazardous Waste POL – Petroleum, Oil and Lubricants Thule AB – Thule Air Base VS/ESH – Vectrus Services A/S Environment Safety and Health.

UXO – Unexploded Ordnance

10 DEFINITIONS

Standard Definitions (Applicable to all AF Installations)

HW Playbook – Definitions Section

Closed Container – A HW container where the lid is fastened with locking rings or bungs wrench-tight.

Container – Any device, in which a material is stored, transported, treated, disposed of, or otherwise handled.

CONUS – The Contiguous United States; 48 of the States excluding Alaska and Hawaii.

Disposal – The utilization of those methods of treatment and/or containment technologies, as are approved in the FGS, section 11, that effectively mitigate the hazard to human health or the environment of the discharge, deposit, injection, dumping, spilling, leaking, or placing of any HW into, or on any land or water in a manner that, without application of such methods, such hazardous wastes or any constituent thereof may enter the environment or be emitted into the air or discharged into any waters including groundwater.

EESOH-MIS – Enterprise Environmental, Safety and Occupational Health Management Information system is a program used to track hazardous waste generated at Thule AB.

https://static.e-publishing.af.mil/production/1/af_a4/publication/afi32-7001/dafi32-7001.pdf http://static.e-publishing.af.mil/production/1/af_a4/publication/afman32-7002/afman32-7002.pdf http://static.e-publishing.af.mil/production/1/saf_ig/publication/afi90-201/afi90-201.pdf https://usaf.dps.mil/teams/eDASH/Lists/AFLOALegal/AllItems.aspx?FilterField1=Program_x0020_Area&FilterValue1=Hazardous+Waste https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodm/416021_vol4.pdf https://usaf.dps.mil/teams/14074/Module/Home.aspx https://usaf.dps.mil/teams/eDASH/WPP/EAPTool/Program+View.aspx?Program=Hazardous+Waste https://usaf.dps.mil/teams/eDASH/WPP/ProgramPage/ProgramPage.aspx?Program=Hazardous+Waste https://usaf.dps.mil/teams/eDASH/Lists/TrainingMatrix/AllItems.aspx?FilterField1=Program_x0020_Area&FilterValue1=Hazardous+Waste https://www.my.af.mil/esoh/eesoh/ http://www.eesoh-mis.com/ https://usaf.learningbuilder.com/ https://usaf.dps.mil/teams/10041/ceplaybooks/hwmp/pages/overview.aspx https://usaf.dps.mil/teams/eDASH/lists/acronym/allitems.aspx https://usaf.dps.mil/teams/10041/CEPlaybooks/HWMP/Pages/PlaybookProcesses.aspx?PrintOrder=25 https://usaf.dps.mil/teams/10041/CEPlaybooks/HWMP/Pages/PlaybookProcesses.aspx?PrintOrder=26

FGS – Final Governing Standards for Greenland, 2020.

Flash Point – The minimum temperature where there is sufficient vapor to ignite the source, if introduced to an external ignition source.

Generator – Any person or site whose act or process produce HW, identified or listed in the FGS.

Hazardous Waste - Hazardous waste are a discarded material that may be solid, semi-solid, liquid, or contained gas and either exhibits a characteristic of a hazardous waste defined in the FGS in subsection C20.1 Tables AP1.T1 and AP1.T2 or is listed as a hazardous waste in Tables AP1.T3 and AP1.T4. Excluded from this definition are domestic sewage sludge, household wastes, and medical wastes. Waste is hazardous if it can be harmful to human health and the environment when handled improperly.

Hazardous Waste Characterization – HW Characterization is the identification, description, and qualification of a HW stream.

HM – Hazardous Material.

HW – Hazardous Waste as defined in the FGS.

Manifest – The shipping document originated and signed by the generator, which contains the information required by the USEPA.

SDS –Safety Data Sheet (SDS) is a document that lists information relating to occupational safety and health for the use of various substances and products. SDS information may also include spill-handling and disposal procedures.

PCB - A polychlorinated biphenyl (PCB) is an…