ATTACHMENT_TO_AMENDMENT_0001_FILE_1_OF_3.pdf

U. S. AIR FORCE HAZARDOUS WASTE MANAGEMENT PLAN

Malmstrom AFB

2/13/2019

ABOUT THIS PLAN

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

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

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

TABLE OF CONTENTS

DOCUMENT CONTROL

1.0 OVERVIEW AND SCOPE

2.0 INSTALLATION PROFILE

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

4.0 GENERAL ROLES AND RESPONSIBILITIES

5.0 TRAINING

6.0 RECORDKEEPING AND REPORTING

7.0 PROCEDURES

7.1 Waste Inventory

7.2 Waste Identification

7.3 Container Management

7.4. Labeling and Marking

7.5 Accumulation Area Management

7.6 Transportation

7.7 Turn In/Disposal

7.8 Inspection

7.9 Waste Minimization

7.10 Preparedness and Prevention

7.11 Waste Specific Procedures

8.0 REFERENCES

9.0 ACRONYMS

10.0 DEFINITIONS

11.0 INSTALLATION-SPECIFIC CONTENT

APPENDICES

Appendix A – Waste Analysis Plan

Appendix B – Hazardous Waste Profile Sheet Form 1930

Appendix C –Satellite Accumulation Points

Appendix D – MAFB SAP MAP

Appendix E – Waste Profile Sheet On Base

Appendix F – Waste Profile Sheet Missile Field

Appendix G – Missile Field Generated Waste Instructions

Appendix H – SAP, CAP, and TSDF Inspection Checklists

DOCUMENT CONTROL

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

Record of Updates

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

Click here to enter text. Click here to enter text. Click here to enter a date.

Click here to enter text.

Click here to enter text. Click here to enter text. Click here to enter a date.

Click here to enter text.

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

Record of ESOHC Annual Review

Review Date Review Participants Notes/Remarks Result in Plan

Update? (Yes or No) 5/10/2017 SAP Managers, UECs, SWPM, HWPM, P2

Chief, EMS CFT

Plan formatted to standard template format, WAP added as appendix

No

2/13/2019 SAP Managers, UECs, SWPM, HWPM, P2

Chief, EMS CFT

Administrative changes only, update waste stream information

EMS CFT REVIEW

Approval

No

1.0 OVERVIEW AND SCOPE

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

Installation Supplement – Overview and Scope

Congress passed environmental laws requiring the control of hazardous materials and wastes. These statutes include: Resource Conservation and Recovery Act (RCRA) of 1976, Hazardous and Solid Waste Amendments (HSWA), 1984, Toxic Substance Control Act (TSCA), Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Clean Water Act (CWA), Clean Air Act (CAA), and the Federal Facilities Compliance Act (FFCA), 1992. Under these statutes Malmstrom Air Force Base (MAFB) must provide and follow a plan to protect human health and the environment from the improper management of hazardous materials and waste. As the authorized agency for the U.S. Environmental Protection Agency (EPA), the Montana Department of Environmental Quality (MDEQ) retains the rights to inspect MAFB for compliance with these statutes; findings of violations could result in monetary fines. These fines are not paid by environmental funds, but must come from the Operations and Maintenance (O&M) account used to operate the base.

The FFCA states an individual can be held criminally liable for any violation of federal environmental regulations. This plan sets forth procedures to prevent notices of violations, monetary penalties and criminal charges.

Effectively managing hazardous waste is a challenge. To correctly implement installation procedures this plan has been designed to conform to Environmental Management System (EMS) specifications. This plan is a management approach which includes policy development, organizational structure, planning activities, responsibilities, practices, procedures, processes, and resources for developing, implementing and achieving reduction goals and regulatory compliance sustainability.

This plan is reviewed by the ESOH Council annually and will be acknowledged by the signed minutes of that meeting.

2.0 INSTALLATION PROFILE

Installation Profile

Scope of Plan This plan is to be used by Malmstrom AFB organizations that generate, accumulate, monitor, dispose of or respond to incidents involving hazardous waste.

Office of Primary Responsibility

(OPR)

341 CES/CEIE has overall responsibility for implementing the HW management program and is the lead organization for monitoring compliance with applicable federal, state and local regulations

HW Program Manager Leo Semana, 341 CES/CEIE, 731-6163 Alternate HW Program Manager Frank Carpenter, 341 CES/CEIE, 731-6448 Emergency contacts Malmstrom AFB Fire Department, 911, 731-3745/3746

HW Program Manager, 731-6163 Central Accumulation Point Contractor, 731-2337

Waste registration numbers Malmstrom AFB EPA ID MT8571924556 HW generator status Malmstrom AFB – Large quantity generator

Each of the 165 off-base missile facilities is a distinct Conditionally Exempt Small Quantity Generator (CESQG).

Universal waste handler status Small Quantity Handler Permitted HW operations Bldg 1535 (Treatment, Storage and Disposal Facility)

Permit Number MTHWP-12-01 Federal or FGS regulatory references 40 CFR 260 - 299 State and local regulatory agencies Montana Department of Environmental Quality State and local regulatory references Administrative Rules of Montana (ARM) Approved HW disposal contractors DLA Disposition Services HW accumulation sites See Satellite Accumulation Points Table HW accumulation time limits Central Accumulation Point (Bldg. 434: 90 days)

Treatment Storage and Disposal Facility (Bldg.1535: 1 year) HW generator reporting frequency Annual

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

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

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

4.0 GENERAL ROLES AND RESPONSIBILITIES

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

Wing/Installation Commander

ESOHC

HW Manager/Alternate Shop/HW Generator Personnel Initial Accumulation Point (IAP) and Hazardous Waste Accumulation Site (HWAS)

Supervisors/Managers Unit Commanders Unit Environmental Coordinators (UECs), see AFI 32-7001 for role description Contracting Officer Defense Logistics Agency Disposition Services Tenant Organizations

AFCEC

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

Installation Supplement – General Roles and Responsibilities

Responsibilities: The ultimate responsibility for hazardous waste management, as well as the overall responsibility of environmental management at MAFB, lies with the 341st Missile Wing Commander. Due to the complex nature of the installation, squadron commanders will appoint both a primary and alternate hazardous waste monitor for all shops that generate hazardous waste.

These individuals will be responsible for ensuring that waste is accumulated, labeled and stored properly and will coordinate the turn-in of hazardous waste to the central accumulation point (CAP).

They are also required to represent their organization at meetings and during inspections.

Generators: Must operate and maintain the satellite accumulation point (SAP) IAW all federal, state, and local regulations. Ensure that all personnel assigned are appointed in writing by their commander and submitted to CEIE. Generators must ensure that all assigned personnel are properly trained to the appropriate level, all processes are reported to CEIE, each waste stream has the appropriate SDS, each container is properly marked, and full containers are reported and transferred to the CAP within 3 days. For new processes/special projects, generators must coordinate with CEIE to obtain containers to ensure they meet DOT, compatibility and air emission standards. All wastes are profiled for waste determination and profile sheets are maintained and filed in CEIE by the hazardous waste program manager.

5.0 TRAINING

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

Installation Supplement – Training

SAP Training: SAP Training is required annually. MAFB CEIE will provide training for hazardous waste management. The training for personnel responsible for hazardous waste management will include:

a. Resource Conservation and Recovery Act (RCRA) history and the impact it has on MAFB and its mission.

b. Highlighting the rules and regulations for determining identification of hazardous waste.

c. The federal, state and local policy for accumulation point and satellite point management.

d. Proper container use, marking, and labeling to meet DOT requirements.

e. Universal Waste requirements are covered in the initial and refresher training.

f. The base policy on waste turn-in procedures, spill prevention, and emergency response to hazardous material or waste releases is also discussed.

g. Students are also encouraged to use non-hazardous materials to reduce the generation of hazardous waste.

DOT Training: MAFB CEIE Hazardous Section is required to take the tri-annual Transportation of Hazardous Material and Hazardous Waste training.

HAZWOPER 8 Hours Refresher Training: MAFB CEIE Section and CEOHP are required to take a refresher training annually.

Hazardous Waste Awareness Training: SAP Monitors are responsible for teaching Shops specific Hazardous Waste Awareness training to all individuals assigned to their shop. Awareness Training generally consists of instructions regarding satellite point requirements and specific types of waste collected. Awareness Training is required to be conducted annually and must be documented either by an attendance roster, AF Form 1098, or Form 55.

6.0 RECORDKEEPING AND REPORTING

Recordkeeping

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

Summary of HW Recordkeeping Requirements

Record* Retention Time** Citation HW determination documentation

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

40 CFR 262.40

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

40 CFR 262.40

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

40 CFR 262.34

40 CFR 265.15 (d)

40 CFR 265.174

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

Land restricted waste determination

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

40 CFR 268.7

Land restriction notice and certification

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

40 CFR 268.7

Notification of intent to export waste

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

40 CFR 262.53

EPA acknowledgement of consent (for exports)

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

40 CFR 262.51

40 CFR 262.53

Waste export confirmation of delivery

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

40 CFR 262.54

Annual report (required of primary exporters of HW)

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

40 CFR 262.56

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

Current personnel: until closure of the site;

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

40 CFR 262.34

40 CFR 264.16

40 CFR 265.16

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

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

Reporting

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

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

Installation Supplement – Recordkeeping and Reporting

Reporting: 341 CES/CEIE will prepare and submit annual generator and facility reports to the Montana Department of Environmental Quality by March 1st of each year. The annual generator report covers hazardous waste activities for the previous calendar year. 341 CES/CEIE will also prepare and submit an annual facility report as an owner/operator of a permitted hazardous waste management facility. This report covers hazardous waste management activities conducted at the permitted facility during the previous calendar year.

7.0 PROCEDURES

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

7.1 Waste Inventory

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

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

Installation Supplement – Waste Inventory

WASTE STREAM INVENTORY

Waste Stream Location

(Shop Name, Office Symbol, Bldg.)

Waste Steam Number

Description

Estimated Annual

Disposal in Pounds

(lb.)

HW Criteria Exhibited & Concentration Limits

C-Corrosive I-Ignitable

T-Toxic

EPA/State Hazardous Waste ID Number

Disposal Container

Disposal Method

Helicopter Maintenance DSI Maintenance Bldg. 1440 Bay 5

AB0101

Helo Cleaning

(MEK

Contaminated Rags)

20 lbs. T- MEK > F005 DRUM DLA-DS

PO0802

Painting Operations (Paints & Thinners)

40 lbs. T- Sampled Each Time

SAMPLED DRUM DLA-DS

MS0001

Helo Engine Wash Water

600 lbs. T- Toluene Xylene F003 F005 DRUM DLA-DS

Sign Shop

341 CES/CEOHS

Bldg. 471

PO0414

Sign Making (Paints & Thinners)

200 lbs.

I- Flashpoint <140oF

D001 DRUM DLA-DS

MS0049

Xylene Rags

60 lbs. T-Xylenes F003 DRUM DLA-DS

Gen. Purp. Shop

341 LRS/LGRVM

Bldg. 870

FC0512

Vehicle Maintenance (Gasoline Fuel Filters)

60 lbs. T- Benzene >.5 ppm

DO18 DRUM DLA-DS

Allied Trades

341 LRS/LGRVM

Bldg. 910

PO0608

Vehicle Painting (Paints/ Thinners) lbs.

I- Flashpoint 55 of

D001, D035, F003, F005

DRUM DLA-DS

P.R.E.L.

MOS/MXOPP

Bldg. 1439

SC0701

Mixing Sodium Chromate (Chromate Rags)

600 lb. T- Chromium

2.8 ppm

DOO7 DRUM DLA-DS

FC0709

Mixing Sodium Chromate (Sodium Chromate)

650 lb. T- Chromium 137 ppm

DOO7 DRUM DLA-DS

Waste Stream Location

(Shop Name, Office Symbol, Bldg.)

Waste Steam Number

Description

Estimated Annual

Disposal in Pounds

(lb.)

HW Criteria Exhibited & Concentration

Limits C-Corrosive I-Ignitable

T-Toxic

EPA/State Hazardous Waste ID Number

Disposal Container

Disposal Method

RV Maintenance

341 MUNS/WSA

Bldg. 1840

FC0810

Treating Aluminum Surfaces (Alodine Solution)

40 lbs. C- >12.5 pH D002 DRUM DLA-DS

PO0009

Alodine Rags

30 lbs. T-Chromium D007 DRUM DLA-DS

PO0808 Paint and Adhesive Rags

50 lbs. T-Chromium D007 F005 DRUM DLA-DS

PO0815 P-

Nitrophenol Rags

40 lbs. T-P-Nitrophenol U170 DRUM DLA-DS

Corrosion Control

MMXS/MMXSFC

Bldg. 368

FC0905

Corrosion Control (Respirator Filters)

20 lbs. T- Cadmium

7.1 mg/L

D006 DRUM DLA-DS

PO0906

Corrosion Control (Paints & Thinners)

125 lb. I- Flashpoint<50oF T- Chromium

26.8 ppm T- Acetone 28000 ppm

T-MEK 86000

ppm

T-MIK 66000

ppm T-Toluene 98000 ppm T-Xylene 49000 ppm T- Ethyl Benzene 10000 ppm

D001, F002, F003, F005

DRUM DLA-DS

PO0M01 Paint Rags

50 lbs. T-Cadmium T- Lead

D006 D008 F003 F005

DRUM DLA-DS

(Shop Name, Office Symbol, Bldg.)

Waste Steam Number

Description

Estimated Annual

Disposal in Pounds

(lb.)

HW Criteria Exhibited & Concentration Limits

C-Corrosive I-Ignitable

T-Toxic

EPA/State Hazardous Waste ID Number

Disposal Container

Disposal Method

Heavy Equipment

341 LRS/

LGRVM

Bldg. 882

FC1003

Maintenance (Gasoline Fuel Filters)

50 lbs. T- Benzene >.5 ppm

D018 DRUM DLA-DS

Combat Arms

341 SSPTS/S4C

Bldg. 1895 Cleaning Rm.

OD1201

Weapons Cleaning (Lead Contaminated Rags)

300 lb. T- Lead 12.2 ppm D008 DRUM

DLA-DS

OD12003

Firing Range Debris (Lead Dust)

1,000 lb.

T- Lead 3900 ppm D008 DRUM DLA-DS

Missile Field

341 MMXS

Missile Complex

BA0M01

Battery Servicing (Battery Fluid)

60 lb. C- 1.43 pH D002 DRUM DLA-DS

FC0M01

Chiller Maintenance (Sodium Chromate Solution)

500 lb. T- Chromium 361 ppm

D007 DRUM DLA-DS

FC0M02

Chiller Maintenance (Sodium Chromate Rags)

300 lb. T- Chromium 28 ppm

D007

PO0M01

Corrosion Control (Paint Rags)

25 lb. T- Toluene 1200 ppm T-Chromium

7.99 ppm T-Xylene 13000 ppm T- Ethyl Benzene 280 ppm

D007, F003, F005

(Shop Name, Office Symbol, Bldg.)

Waste Steam Number

Description

Estimated Annual

Disposal in Pounds

(lb.)

HW Criteria Exhibited & Concentration Limits

C-Corrosive I-Ignitable

T-Toxic

EPA/State Hazardous Waste ID Number

Disposal Container

Disposal Method

SFG Armory

341 SSPTS/S4A

Bldg. 500

OD1204

Cleaning (Lead Contaminated Rags)

300 lbs. T- Lead 12.2 ppm D008 DRUM DLA-DS

Environmental

341 CES/CEIE

Bldg. 1536

BW0001

BARREL

WASHING

(Wash Water)

4,000 lb.

T-Sampled Each Time

SAMPLED DRUM DLA-DS

BW0002

BARREL

WASHING

(Rinse Water)

3,000 lb.

T-Sampled Each Time

SAMPLED DRUM DLA-DS

BW0003

BARREL

WASHING

(Barrel Residue)

150 lb.

T-Sampled Each Time

SAMPLED DRUM DLA-DS

PO0001

Paint Consolidation (Waste Paints & Thinners)

500 lb. I- FLASHPOINT <140oF T- Sampled Each Time

D001, SAMPLED

DRUM DLA-DS

P.R.E.L.

MOS/MXOPP

Bldg. 1439

BA0701

Battery Servicing (Battery Fluid)

150 lb. C- 1.43 pH D002 DRUM DLA-DS

Tactical Response Force

341 SSPTS/TRF

Bldg. 250

OD1205

Cleaning (Lead Contaminated Rags)

300 lbs. T- Lead 12.2 ppm D008 DRUM DLA-DS

Auto Hobby Shop 341 FSS/Auto Hobby Bldg. 1248

PO0006

Vehicle Painting (Paints/ Thinners)

250 lbs. I- Flashpoint 55 of

D001, D035, F003, F005

Waste Steam Location (Shop

Name, Office Symbol, Bldg.)

Waste Stream Number

Description

Estimated Annual

Disposal in Pounds

(lb.)

HW Criteria Exhibited & Concentration Limits

C-Corrosive I-Ignitable

T-Toxic

EPA/State Hazardous Waste ID Number

Disposal Container

Disposal Method

Auto Hobby Shop 341 FSS/Auto Hobby Bldg. 1248 (Continued)

MS0014

Vehicle Maintenance (Gasoline Fuel Filters)

50 lbs. T- Benzene >.5 ppm

D018 DRUM DLA-DS

MS0044

Vehicle Maintenance (Gasoline Rags)

20 lbs. T- Benzene >.5 ppm

D018 DRUM DLA-DS

Electronic Laboratory

341 MOS/MXOP

Bldg. 780

MS0045

Cork Repair

30 lbs. T-Lead >5.0 ppm

D008 DRUM DLA-DS

Electronic Laboratory

341 MOS/MXOP

Bldg. 780

FC0701

Sodium Chromate Rags

50 lbs. T-Chromium

5.0 ppm

D007 Drum DLA-DS

Electronic Laboratory

341 MOS/MXOP

Bldg. 780

PO0009B

Alodine Rags

40 lbs. T-Chromium >5.0 ppm

D007 Drum DLA-DS

LRS Mobility 341 LRS/Mobility Bldg. 3080

OD1206

Weapons Cleaning (Lead Contaminated Rags)

200 lbs. T- Lead >5.0 ppm

D008 DRUM DLA-DS

MS0046

Gas Mask Filter

100 lbs. T-Chromium >5.0 ppm Silver >5.0 ppm

D007 D011 DRUM DLA-DS

RHS/SUPPLY

819 RHS/LGS

Bldg. 1464

OD1207

Weapons Cleaning (Lead Contaminated Rags)

200 lbs. T- Lead >5.0 ppm

D008 DRUM DLA-DS

Location (Shop

Name, Office Symbol, Bldg.)

Waste Steam Number Description

Estimated Annual Disposal in Pounds (lb.)

HW Criteria Exhibited & Concentration Limits

C-Corrosive I-Ignitable

T-Toxic

EPA/State Hazardous Waste ID Number

Disposal Container

Disposal Method

Pharmacy

341MDSS/SGSD

Bldg. 2040

MS0008

Empty Coumadin Bottles and Pills

30 lbs. T-Warfarin P001 DRUM DLA-DS

819 RHS/Vehicle

819 RHS/LGTM

Bldg. 1450

MS0047

Maintenance (Gasoline Fuel Filters)

20 lbs. T- Benzene >.5 ppm

D018 DRUM DLA-DS

RV Maintenance

341 MUNS/WSA

Bldg. 1840

MS0048

91B Mixed Waste

75 lbs. T-Cadmium >1.0 ppm

D006 F005 DRUM AFRAD

RHS/SUPPLY

819 RHS/LGS

Bldg. 1466

OD1207

Weapons Cleaning (Lead Contaminated Rags)

200 lbs. T- Lead >5.0 ppm

D008 DRUM DLA-DS

7.2 Waste Identification

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

(WAP).

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

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

Installation Supplement – Waste Identification

See Appendix A - Waste Analysis Plan

7.3 Container Management

Container management procedures are as follows:

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

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

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

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

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

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

Installation Supplement – Container Management

7.4. Labeling and Marking

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

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

a. The words “Hazardous Waste”

b. A description of the contents of the container

c. The hazards associated with the waste

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

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

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

b. Generator’s name and address

c. Generator’s EPA Identification Number

d. Manifest tracking

These markings are:

a. Durable

b. In English, and/or appropriate host nation language

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

d. Unobscured by labels or other attachments

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

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

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

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

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

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

Installation Supplement – Labeling and Marking

7.5 Accumulation Area Management

Accumulation area management procedures are as follows:

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

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

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

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

Installation Supplement – Accumulation Area Management

REQUIREMENTS FOR SATELLITE ACCUMULATION POINTS (SAP)

General Requirements

1. Manage only those wastes generated in your shop. Don’t accept hazardous waste from another shop or squadron.

2. Identify all hazardous wastes generated. If your shop begins a new process that generates a new waste stream, contact Hazardous Material (EESOH-MIS) 731-6441 to determine if the new waste is hazardous.

3. Disposal cost is determined by weight. Reducing the amount of waste generated reduces the cost/liability associated with waste management, so every effort should be made to minimize.

Satellite Accumulation

1. Up to 55 gallons of hazardous waste are allowed at each satellite point.

2. SAPs must be at or near the point of generation and under the control of the operator.

3. Containers must be marked with the words “Hazardous Waste” or “Waste” with other words that identify the contents.

4. Containers must be kept closed at all times, unless waste is being added to or taken away from the container.

5. Each SAP must have a sign identifying the area as a satellite area.

SAP Book

1. Every shop that accumulates hazardous waste must have a SAP book that is readily available for inspection at any time during working hours.

2. A current appointment letter signed by each squadron’s commander identifying the satellite manager and alternate. A copy of this letter must also be sent to the Environmental Management office (341CES/CEIE).

3. The current copy of the base Hazardous Waste Management Plan and your site specific Emergency Spill Response plan.

4. Document your Haz Waste Training for your monitor and alternate, and the awareness training for the rest of the shop using a sign in sheet, certificates, AF Form 55, or AF Form 1098

5. Maintain weekly inspection log of SAP.

7.6 Transportation

The HW Manager has overall responsibility for the transportation of HW from an IAP to an HWAS, and from an HWAS to the disposal facility. The HW Manager ensures:

All transportation over public highways is conducted IAW applicable DOT requirements.

Containers are DOT approved.

Transporters have the appropriate training.

Uniform Hazardous Waste Manifest are prepared for offsite transportation.

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

Installation Supplement – Transportation

Missile field generated waste is considered Small Quantity Conditionally Exempt Waste while being transported from the missile field back to the base support facilities. It is then placed in the transport vehicle in building 1440, 341 MMXS facility, for pick up by 341 CES/CEIE hazardous waste management. In accordance with agreement between Malmstrom AFB and MT DEQ dated Sept 2012

7.7 Turn In/Disposal

The turn in procedures contained in DoD 4160.12-M. DLA Disposition Services are followed. In the event an alternate route for disposal 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 are transferred to a container that is in good condition.

Installation Supplement – Turn In/Disposal

Routine Waste: If the waste has a National Stock Number (NSN), the items must be turned in by NSN, separated, counted and have an individual SDS for each stock number and manufacturer. If the waste is a profiled waste it may be turned in without an SDS and without a NSN.

Non-Routine Waste: If the waste is something not common to your operation, recently found materials, residue from a spill cleanup, or has expired shelf life, the shop will provide CEIE with the SDS and the process (if known) in which the item was used.

Call CEIE at 731-2337or 731-6163 for containers and to schedule a pick-up.

Central Accumulation Point: Managed by contracted environmental personnel who coordinate the pickup, transportation, reutilization, and disposal for all hazardous waste and used petroleum turn-ins. They maintain the inspection / inventory logs, and generator pickup schedule.

CAP personnel must adhere to all regulatory compliance requirements for management of a 90 day Hazardous Waste Storage Facility and inspect the SAP’s for compliance during visits. They requisition and issue the appropriate DOT-approved containers to generators, ensuring the compatibility of the container to the waste, and ensure that containers meet hazardous waste air emissions standards.

7.8 Inspection

Inspection processes fulfill the “Check” function of the EMS “Plan, Do, Check, Act” cycle. HWASs are inspected at least weekly to ensure proper accumulation and container management. RCRA Part B permitted storage facilities are inspected according to the inspection schedule established in the permit.

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.

Installation Supplement – Inspection

Inspection Checklists are located in Appendix H

TSDF: Weekly inspection

CAP: Weekly inspection

SAP: Weekly inspection by SAP manager. SAPs are inspected quarterly by the HW contractor.

7.9 Waste Minimization

HW 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 Manager, 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

Environmental action planning – Environmental action plans (EAPs) are developed and maintained as part of the overall EMS. EAPs are management plans that translate environmental objectives and targets into actionable plans. Waste minimization efforts are considered during development of EAPs

Installation Supplement – Waste Minimization

Incorporate installation-specific content

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.

Installation Supplement – Preparedness and Prevention

Contingency Plan Summary Persons discovering spills are responsible for providing initial defense actions without undue risk of personal injury. Upon initial discovery, the following steps will be taken:

a. Initiate evacuation, unless the person discovering the spill has absolute knowledge that no hazards exist for personnel in the area. If evacuation is initiated, bring the Safety Data Sheet (SDS) of the spilled material.

b. Notify Fire Protection: Dial 911 from a Base phone, 731-3745/3746 from a cell phone.

c. Stop the spill at its source without risking personal safety or the safety of others. If uncertainty exists, wait for Fire Protection to arrive.

d. Report all spills to the work area supervisor. The supervisor will then make the decision on how to handle the situation based on the size of the spill and SDS information.

e. Initiate containment and cleanup operations as directed by On-Scene Coordinator (OSC).

f. Make spill scene "OFF LIMITS" to unauthorized personnel.

g. Restrict all sources of ignition when flammable substances are involved.

h. Report to the designated OSC upon his/her arrival.

Notifications and reporting requirements are listed in the SPCC Plan

Contingency Plan for Failure of Disposal Contract If the DLADS Hazardous Waste contract should fail, the following procedures will be followed by the Hazardous Waste Program Manager for disposal of hazardous waste:

Select company from approved transporter list to transport waste to Treatment, Storage, and Disposal Facility (TSDF).

Approved TSDF will be contacted and inspected to ensure it meets federal standards for disposal.

Proper documents will be completed for waste offered for shipment.

Appointment made with TSDF and transporter for shipping and disposal.

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.

Installation Supplement – Waste Specific Procedures

Base Specific Procedures/Guidance The following are MAFB specific procedures used to manage commonly generated items.

Aerosol Cans Empty cans or cans that are no longer functioning must be managed as a hazardous waste. For shops that have a satellite accumulation point (SAP), aerosol cans must be placed into the Hazardous Waste Aerosol Container.

For shops that generate small quantities that do not have a SAP, empty cans must be taken immediately to the Central Accumulation Point.

Do not store empty aerosol cans in the shop or in a flammable locker. One shop cannot take their empty cans to another shop’s SAP.

Once the aerosol cans have been delivered to the CAP, personnel will determine whether the cans can be repaired and placed back into service or are no longer usable. Cans that are determined to be unusable, will be punctured by CAP personnel to relieve the pressure, contents will be collected as hazardous waste and the empty can will be collected as scrap metal.

Batteries There have been several incidents involving used batteries that have shorted out with each other and have caused fires. The reason this occurred is because no action was taken to prevent short circuiting.

Therefore, all batteries, regardless of type and/or final disposition, will be individually placed into a zip lock style baggie or taped in a manner that covers the terminal ends to protect from shorting.

The following disposition guidance is provided by battery type:

Battery Type Category Disposal Method alkaline Non-RCRA bag or tape / throw away carbon zinc Non-RCRA bag or tape / throw away nickel cadmium wet Hazardous bag or tape / turn in to P2 lead acid - wet Recycled Material turn in to P2/QRP lead acid – sealed Recycled Material turn in to P2/QRP nickel cadmium Universal waste bag or tape / turn in to P2 mercury Universal waste bag or tape / turn in to P2 silver oxide Universal waste bag or tape / turn in to P2 lithium Universal waste bag or tape / turn in to P2 magnesium Universal waste bag or tape / turn in to P2 nickel metal hydride Universal waste bag or tape / turn in to P2

i. Universal Waste Battery Containers should be marked "Universal Waste and identify the type of battery, for example: “Universal Waste – NiCad Batteries”. Containers must also be marked with the date the first battery was placed in the container and terminals are taped.

j. Container must be kept closed at all times, unless items are being added or removed from the container and all terminals are taped.

k. Shops must turn Universal Waste in to the CAP no longer than 9 months after accumulation start date to allow processing time for items to be shipped off site for recycling.

C2/C2A1 Canisters Unopened C2A1 canisters, NSN 4240-01-361-1319, and unopened C2 canisters, NSN 4240-01-119- 2315, that have shelf-life remaining will be turned-in at base supply as a serviceable material.

Expired or unneeded C2A1 (Green) canisters, NSN 4240-01-361-1319, that are opened or unopened will be turned-in at Base Supply with a safety data sheet as unserviceable material and shipped to the Defense Logistics Agency Dispostion Services (DLADS) for DEMIL destruction.

These canisters are not hazardous waste and will not be accepted by CEIE. Note: These items can still be used for training.

Expired C2 (Black) canisters (opened or unopened), NSN 4240-01-119-2315, must be disposed of as hazardous waste through the Central Accumulation Point (CAP).

C2 canisters that will be disposed as hazardous waste will be collected and stored in a Satellite Accumulation Point (SAP). Containers should be marked as hazardous waste and labeled expired C2 canisters.

Fuel Rags/Absorbents Fuel rag and absorbent disposal is based upon the type of fuel used and whether or not the rag / absorbent are saturated. Saturated is defined as: If you wring the rag/pad and see free flowing liquid, then the item is considered saturated and if no liquid comes out, it is considered to be non-saturated.

All rags and absorbents must be double bagged.

Note: In an effort to reduce waste and meet reduction requirements, every effort must be made to wring/recycle fuel from absorbents. The following guidance is provided by fuel type:

Waste Results Disposal Absorbents or Rags w/ Mo-Gas Hazardous Turn in to CAP Absorbents or Rags w/ Jet A Non-hazardous Turn in to P2 Absorbents or Rags w/ Diesel Non-hazardous Turn in to P2

Fuel/POL Filters Filter management is based upon the type of fuel/POL that the filter was used for. The following guidance is provided by fuel/POL type:

Waste Disposal Oil / Hydraulic Filters Hot-drain for 24 hours and collect as scrap metal Mogas Filters Hazardous/must be collected in SAP and turned into CAP Jet A/Diesel Filters Drain for 24 hours into “Used Fuel” container. A hard cover must be placed over this process to reduce air emissions releases and ensure compliance.

Metal Filters should be recycled

Plastic/paper ensure that they are not saturated and discard in the trash

POL Liquids POL management is based upon the type of POL collected.

Waste Disposal Used Oil Collect in container labeled as “Used Oil”/notify CAP Used Jet A/Diesel Collect in container labeled as “Used Fuel”/notify CAP Hydraulic Fluid Collect in container labeled “Used Hydraulic Fluid”/notify CAP Mogas/Diesel Contaminated gasoline or if gasoline is mistakenly put into diesel vehicles. Collect in container labeled “Hazardous Waste”/notify CAP

Parts Washer Jet washer/parts washer cleaners must be changed according to manufacturer’s recommendations to prevent concentrations of heavy metals. Metals and debris in the solution settle to the bottom of the machine creating a hazardous sludge. Since it is hazardous, the sludge must drain into a hazardous waste container via a closed loop process. An example of this would be a hose or tubing that is plumed from the unit into a closed collection container. The container must be placed in a drip pan to contain any possible spills.

Lamps Light Bulbs are products that nearly every shop on Malmstrom utilizes. The Montana Department of Environmental Quality has adopted the Universal Waste Regulations from the EPA for certain bulbs. The following guidance is by bulb type:

Bulb Type Category Disposal Fluorescent Universal Waste Turn into P2 HID Universal Waste Turn into P2 High Pressure Sodium Universal Waste Turn into P2 Mercury Vapor Universal Waste Turn into P2 Metal Halide Universal Waste Turn into P2 Incandescent Non-Hazardous Throw into trash

Note: Shops that generate a low volume of bulbs are permitted to immediately take bulbs to the CAP for recycling instead of collecting.

Universal Waste Lamps:

e. Work centers that choose to manage spent lamps will collect them in a container/box marked as “Universal Waste – Lamps”

f. Date the box at the time the first spent lamp is collected

g. The box must be closed at all times, unless adding items to or taking items away

h. “Universal Waste Lamps” can be accumulated on Malmstrom AFB up on one (1) year;

however shops must turn-in collected spent lamps to the CAP 9 months after accumulation start date to be shipped off-site for recycling.

Lead Solder All soldering residue (i.e., pieces of solder, flakes, droppings etc.) to include silver, lead or tin solder will be collected and turned in as scrap metal.

f. Suggest a small container labeled “Recycled Metal” be placed near the process and turned in for recycle when full.

g. Soldering equipment (i.e., soldering tips, wicks, etc.) will also be collected and recycled

h. Cleaning equipment (i.e., sponges, tissue paper, solder suckers, etc.) that is worn out and requires disposal will be collected and immediately turned into the CAP for disposal.

Sealants There are currently several types of sealants used here at Malmstrom. Specific guidance has been given to each of the shops that use sealants and SAPs have been established as required.

Please contact the Hazardous Waste Program Manager at 731-6163 if a new process or new type of sealant is required.

Lead Based Paint Non-facility projects involving abatement of suspected lead based paint will follow procedures below: representative samples of suspected paint will be collected and analyzed using Total Characteristic Leaching Procedure for Lead (TCLP-Lead). The regulatory TCLP level is 5.0 mg/L.

If sample is above the regulatory level the abated paint will be collected and turned in at the CAP for proper disposal through the hazardous waste contract.

8.0 REFERENCES

Standard References (Applicable to all AF Installations)

ADLS – Advanced Distributed Learning Service AFI 32-7001, Environmental Management AFI 32-7042, Waste Management AFI 32-7086, Hazardous Materials Management AFI 90-201, The Air Force Inspection System AFLOA HW Legal and Other Requirements – The Air Force Legal Operations Authority

(AFLOA) legal registry lists and provides access to federal (e.g., CFR, U.S. Code), DoD, AF and other legal requirements

ARCNet – Training resource for Air Force Reserve Command DoD 4160.21-M, Defense Reutilization and Marketing Manual EASI Database (includes SIRIS) eDASH Environmental Action Plan (EAP) eDASH Hazardous Waste Home Page eDASH Hazardous Waste Training Matrix EESOH-MIS Software Module Environmental, Safety & Occupational Health Training Network (ESOH-TN) Hazardous Waste Playbook

Installation References

AF Form 2005

9.0 ACRONYMS

Standard Acronyms (Applicable to all AF Installations) eDASH Acronym Library Hazardous Waste Playbook – Acronym Section U.S. EPA Terms & Acronyms

Installation Acronyms

Incorporate installation-specific content

10.0 DEFINITIONS

Standard Definitions (Applicable to all AF Installations)

Hazardous Waste Playbook – Definitions Section

Installation Definitions

Central Accumulation Point (CAP): A consolidated temporary hazardous waste storage area that must not exceed 90 days from the time the waste begins to accumulate at the site. It is managed by 341 CEIE and contract environmental personnel to receive all hazardous waste from on-base facilities and tenant organizations. CAP personnel are located in Bldg. 436, they can be reached at extension 731-2337 or 731-6163.

Container: Any portable device, in which material or waste is stored, transported, treated, disposed of, or otherwise handled in accordance with (IAW) 40 Code of Federal Regulations (CFR) Part 260.10. These containers must be in good condition, free of dents, rust or other forms of damage.

Contingency and Preparedness/Prevention Plan: A hard copy of the contingency plan is located at the 90-Day Central Accumulation Point (CAP) and is also available electronically on the server at: J:\CEI/CEIE\CEANP\Hazardous Waste\90 day Yard Site Specific Emergency Action Plan.

Each SAP has spill prevention equipment that is specifically designed to respond to any release of waste accumulated at that site. (i.e., pads, absorbents, boom, etc.)

Generator: Any person who creates a hazardous waste by act or process, whose employment is on the facilities on MAFB, MT including contractors and tenant organizations.

Hazardous Material: Any material designated as posing a threat to human health or the environment as listed in 49 CFR 171.8.

Hazardous Waste: Any waste that is defined in 40 CFR 261.3, which is usually determined to be ignitable, corrosive, reactive, toxic, or listed in the 40 CFR 261.31-33. These can be materials that are no longer used for their intended purpose or have exhausted their shelf life.

Routine Waste a waste that is generated on a routine basis by a shop or process that has been characterized and profiled.

Non-Routine Waste a waste that is from a new process, a one-time generation, a discovered or unknown waste, or just not routinely generated in that shop or process.

Hazardous Waste Release and Reporting Procedures: Any accidental or intentional spilling, leaking, pumping, pouring, emitting, emptying, or dumping of hazardous materials or waste onto any surface areas or into any waters. These releases need to follow the MAFB Spill Plan (SPCC) for reporting procedures.

Satellite Accumulation Point (SAP): A SAP is an area located at or near the point of generation of a hazardous waste, where less than 55 gallons of hazardous waste are accumulated prior to turn-in to the CAP. Each SAP will have an appointed Monitor and Alternate; they are designated in writing by their commander, and will serve as his/her official representative in all matters of that SAP. Their actions or failure to comply may result in noncompliance, which could result in fines or criminal judgments. Each SAP shall have a sign posted identifying hazardous waste stored in this area. Monitors can contact the Hazardous Waste Program Manager at 731-6163 to obtain a sign if you do not have one.

Saturated: Saturated is defined as: If you wring the rag/pad and see free flowing liquid present, then the item is considered saturated and if no liquid comes out, it is considered to be non-saturated.

Solid Waste: As defined under 40 CFR 261.2, any discarded material, which is abandoned, recycled, or inherently waste-like. Abandoned being disposed of, burned, incinerated, accumulated, stored, or treated. Recycled meaning used in a manner constituting disposal, burned for energy recovery, reclaimed, or accumulated speculatively. Inherently waste-like includes some “F” listed waste after recycling, secondary materials exhibiting a characteristic of a hazardous waste. Materials, which are excluded, are household waste, domestic sewage, industrial wastewater, etc. (See listing in 40 CFR 261.4).

Treatment: Any dilution, addition, or process that changes the chemical make-up of the hazardous waste.

Universal Waste: The rule used for management and disposition of all batteries (except lead acid), mercury thermostats, used antifreeze, fluorescent bulbs, and recalled pesticide stocks.