CAFB HWMP.pdf

U. S. AIR FORCE

HAZARDOUS WASTE MANAGEMENT PLAN

Cannon Air Force Base and Melrose Air Force Range

31 May 2017

Updated: May 2021

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. This plan is not an inventory of all hazardous waste (HW) requirements and practices. Where applicable, external resources and associated document links, including Air Force Instructions (AFIs); Air Force Manuals (AFMANs); AF Playbooks;

and federal, state, local, and permit requirements, are referenced to ensure current content.

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 state, local, and installation-specific requirements and processes. Installation sections are maintained and updated by the installation HW Program Manager and/or the AFCEC Section 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.

TABLE OF CONTENTS

DOCUMENT CONTROL

Standardized HWMP Template

Installation HWMP

1.0 OVERVIEW AND SCOPE

2.0 INSTALLATION PROFILE

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

4.0 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

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 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, they should refer to the eDASH EMP Repository to ensure they have the most current version.

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 the Environmental Protection Agency (EPA) ID assigned to 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, 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. HWMP. Because this is not a contingency plan, coordination should be with Emergency 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 Updates

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

Updated to 2018 AFCEC template

Feb 20

TEDDY M. SUGGS, REM

Hazardous Waste Program Manager, 27 SOCES/CEIE

Updated to reflect new USEPA requirements

Feb 20

Updated to provide better examples to customers

Feb 20

Incorporates requirements from/references to AFMAN 32- 7002; now includes App A (HW Stream Inventory)

Feb 20

Updated POCs as applicable April 21

BRITTNEY LYTLE

Hazardous Waste Program Manager, 27 SOCES/CEIE

Updated HW Stream Inventory April 21

Minor administrative changes April 21

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 HW generating organizations.

Record of EMS CFT Annual Review

Review Date EMS CFT Chair Notes/Remarks

27 Feb 20

JOHN P. BOUDREAUX, COL, USAF

Chairman, 27 SOW CFT Forwarded to ESOHC for approval

6 Apr 20

ROBERT A. MASAITIS, COL, USAF

Commander, 27 SOW Approved

13 May 21 TODD E. RANDOLPH, COL, USAF Commander, 27 SOMSG

Approved

1.0 OVERVIEW AND SCOPE

This HWMP contains procedures for management of HW. In lieu of federal, or state requirements, AFMAN 32-7002, acts as the main driver for the HWMP. The HW Playbook serves as supplemental guidance to this plan. Where applicable, DoD, AF, and Federal Resource Conservation and Recovery Act (RCRA) requirements are included. Each installation must include supplements as warranted to address applicable State and/or local HW requirements/procedures.

Installation Supplement – Overview and Scope

This plan provides policies and procedures for the management of HW generated during base operations at Cannon Air Force Base (AFB) and Melrose Air Force Range (AFR). Cannon AFB and Melrose AFR are committed to the proper management of HW from the point of generation (point at which it becomes a waste) to the point of ultimate disposal. The scope of the plan is the implementation of the U.S. EPA’s “cradle-to-grave” philosophy for managing HW.

2.0 INSTALLATION PROFILE

Installation Profile

Scope of Plan Cannon Air Force Base and Melrose Air Force Range OPR 27 SOCES/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 Brittney Lytle Alternate HW Program Manager Joaquin Madril Emergency contacts

(See Appendix K for additional contact information.)

Brittney Lytle 575.904.6736 brittney.lytle.1@us.af.mil

Sarah Jennings 575.904.3233 sarah.jennings.1@us.af.mil

Joaquin Madril 575.904.6745 joaquin.madril@us.af.mil

Pending 575.904.6747

Pending 575.784.1146

Waste registration numbers Cannon AFB: NM7572124454 Melrose AFR: NM5572124456

HW generator status Cannon AFB: Large Quantity Generator (LQG) Melrose AFR: Very Small Quantity Generator (VSQG)

Universal waste handler status Cannon AFB: Small Quantity Handler of Universal Waste Melrose AFR: Small Quantity Handler of Universal Waste

Permitted HW operations NA Federal regulatory references 40 CFR 260-279 State and local regulatory agencies New Mexico Environment Department (NMED) State and local regulatory references 20.4.1 – 20.4.3 NMAC Approved HW disposal contractors Defense Logistics Agency (DLA) HW accumulation sites Hazardous Waste Accumulation Site (HWAS), also referenced as Central Accumulation Area (CAA), located at Building 226

HW accumulation time limits Cannon AFB: 90 Days Melrose AFR: None

HW generator reporting frequency Cannon AFB and Melrose AFR provides a HW Business Fee annually, as well as a waste report biennially to the USEPA by March 1st of each even-numbered year.

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

The AF 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.

Environmental Action Plans (EAPs) are developed and maintained as part of the overall EMS on eDASH.

EAPs are tools that translate environmental requirements and targets into actionable plans for the HWPM and responsible personnel. HW requirements should be incorporated in installation EAPs to record monitoring and conformance for inspections and audits.

4.0 ROLES AND RESPONSIBILITIES

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

Wing/Installation Commander

ESOHC

EMS CFT

HW Program Manager/Alternate(s) Shop/HW Generator Personnel Initial Accumulation Point (IAP)/ Satellite Accumulation Area (SAA) 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 (DLA-DS) Tenant Organizations

AFCEC

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

Installation Supplement – General Roles and Responsibilities

4.1 27th Special Operations Wing Commander (27 SOW/CC) –

Establishes and maintains the HW Program, to ensure environmental compliance discipline and responsible resource management principles are emphasized and incorporated in installation activities.

Ensures the HW Program is managed to comply with all applicable federal, state, DoD and AF requirements.

Ensures installation organizations that award contracts with potential for generating waste consults with 27 Special Operations Civil Engineer Squadron Environmental Element (SOCES/CEIE).

Ensures the installation, as a potential generator of HW, establishes a HW program in accordance with Air Force Policy Directive (AFPD) 32-70, to ensure compliance AFMAN 32-7002, and all applicable federal, state, and local laws and regulations.

Delegates or designates in writing authority to DLA-DS representative and/or trained 27 SOCES/CEIE personnel to sign Uniform HW Manifests for off-site waste shipments.

Ensures the installation accomplishes appropriate management and disposal of military munitions or material potentially presenting an explosive hazard as required by federal/state law, and DOD/AF regulations.

Approves the HWMP and ensures installation compliance; approval can be via signature or as documented in appropriate ESOHC minutes.

4.1.1 Staff Judge Advocate (27 SOW/JA) –

Reviews draft permits and proposed federal, state, and local rules and protocols and provide comments to the Installation Environmental Element.

Provides consultation for appropriate aspects of the installation HW Program (to include permits, compliance requirements, and funding) and coordinate with the MAJCOM JA, as appropriate.

4.1.2 Public Affairs (27 SOW/PA) –

Advises on public affairs aspect of HW management.

Acts as the only spokesperson and releasing agent to civilian news media regarding a HW incident/accident. If media contact a base agency, they will be referred to 27 SOW/PA without comment regarding the incident/accident.

4.1.3 Ground Safety (27 SOW/SEG) –

Provides technical advice on personnel safety aspects of HW management.

Ensures Job Safety Training Outlines (JSTOs) and AF Forms 55 are appropriately annotated with

HW-related duties/training requirements.

4.2 Base Civil Engineer (27 SOCES/CC) –

The Base Civil Engineer (BCE) is the installation commander’s point of contact responsible for ensuring that solid waste (SW) and HW management installation processes and support services are in compliance with applicable Federal, State, DoD and AF HW requirements. The BCE, through the 27 SOCES/CEIE provides overall management of the HW Program. The BCE:

Acts, in concert with AFCEC/CZ and installation JA, as the liaison office for environmental compliance issues with regulatory agencies, in accordance with other applicable policy.

Ensures adequate recordkeeping processes on base in order to retain all HW notices, certifications, manifests, disposal shipping documents, audit results (on and off-base) and waste analyses, in accordance with environmental regulatory recordkeeping requirements.

Ensures that the installation unit commanders owning HW generating activities will endeavor to reduce pollution at the source.

4.2.1 Installation Environmental Element (27 SOCES/CEIE) –

27 SOCES/CEIE, under the BCE, executes the HWMP. Such support includes:

Assist the installation commander to ensure compliance with all applicable federal, state, DoD and AF HW requirements.

In coordination with AFCEC/CZ, acts as the liaison office for HW compliance and resource management issues with regulatory agencies, and with both internal and external audit personnel.

Identify and arrange for HW sampling, analysis, and monitoring to support compliance on the installation, including as required for generator waste determinations; ensures Quality Assurance in carrying out environmental sampling and testing programs.

Initiate, develop, submit, or participate in funding requests for compliance with HW requirements, regardless of fund source.

Establish local procedures and provide technical expertise with regard to HW compliance and resource management requirements.

Provide education and training, to include shop level training, to meet applicable federal, state, DoD and AF HW requirements.

Conduct periodic compliance self-assessments in accordance with AFI 32-7001, using shop-level and programmatic inspection checklists, and document inspections and findings in the Findings Tracker tool on the AFCEC SharePoint® site, “eDASH”.

Develop and maintain the 27 SOW HWMP as necessary to ensure all Federal, State, DoD and AF requirements are met; coordinates annual reviews with the 27 SOW EMS CFT; substantive revisions will require coordination/approval by the Installation Commander as determined by the CFT. At a minimum, the HWMP will include:

- HW Stream Inventory

- Waste Analysis Plan (WAP)

- HW Training Plan

- Inspection Forms

Document the appropriate waste stream description in EESOH-MIS for the generation of DLA Form 2511, Hazardous Waste Profile Sheet.

Coordinate the disposal of radioactive waste (RW) and mixed waste (MW) with the Installation Radiation Safety Officer (RSO).

In coordination with the 27 SOW/JA, interact closely with the service-appointed DoD Regional Environmental Coordinator to determine and understand the extent of state adoption of the DoD Military Munitions Rule (MR) and associated implementation procedures.

4.2.2 Hazardous Waste Managers at Hazardous Waste Accumulation Site –

Ensures the accumulation area complies with this HWMP and all federal, state, and AF regulations.

Ensures any person handling waste has received the required HW training.

Coordinates all Cannon AFB HWAS procedures through the Environmental Element.

Ensures weekly inspections, not to exceed seven days, are accomplished on each HWAS.

Maintains a current container log that includes the following information (refer to Appendix C):

- Date and location where waste was accepted

- Unit from whom waste was received

- Contents of container

- Container number, type and quantity of containers, and weight

- Organization, office symbol, and phone number of the generator

- Date waste was removed from the installation (or consolidated into bulk packaging)

- Manifest number where waste was removed

Ensures containers are compatible with waste they contain and are in good condition.

Ensures each container is kept closed except to add or remove waste.

Ensures each waste container displays the proper label (HW, non- RCRA regulated), contents of the container, and accumulation start date if it contains HW.

Ensures immediate remedial action is taken for leaks or spills of waste.

Ensures the accumulation site has required fire protection, spill control, and decontamination equipment; communication or alarm system; and aisle space for emergency equipment.

Ensures equipment is tested and maintained to assure its proper operation in time of emergency.

Ensures the accumulation site has a contingency plan as specified in 40 Code of Federal

Regulations (CFR) 265, Subpart D.

Acts as HWAS first responder to incidents until emergency coordinators arrive on- site.

Notifies Environmental Element of any change in facility equipment, operations, or processes.

Maintains a copy of the container (drum) log for three years (contractor submits originals to

Environmental Element).

4.2.3 Hazardous Waste Contractors/Agents (HWAS Personnel) (27 SOCES/CEIE) –

Manages the Cannon AFB HWAS to comply with RCRA requirements.

Picks up HW from industrial shop IAPs/Satellite Accumulation Areas (SAAs).

Logs waste information into EESOH-MIS.

Provides pre-labeled, Department of Transportation (DOT)-approved HW containers appropriate for the waste stream to the IAP.

Provides the HW Program Manager with reports and original document records for the Cannon

AFB HWAS operating records.

Develops Hazardous Waste Profile Sheets (HWPS).

Completes HW labels as necessary for off-site highway shipment.

Coordinates pick-up of waste by the DLA-DS representative after all paperwork is complete.

Diverts waste using a variety of recycling techniques, such as aerosol can puncturing, oil and antifreeze recycling, etc.

Complies with their Statement of Work and contract requirements.

Manages the HW analysis contract.

4.2.4 Base Fire Chief (27 SOCES/CEF) –

Provides technical guidance on fire protection aspects of HW management and training.

Performs annual inspections of all facilities where HW is generated to ensure fire protection regulations are being followed.

Provides initial response to hazardous materials/waste spills.

4.2.5 Explosive Ordnance Disposal (27 SOCES/CED) –

Provides immediate response to requests from law enforcement and other agencies to respond to emergencies involving explosive substances (e.g., explosive devises, military ordnance, and explosive chemical) by detonation on-site or removal to a secure location for detonation.

4.3 Potential HW Generating Activity –

Generating Activities are organizations (including AF and non-AF tenants), shops, or work areas using an operation or process that may first generate a HW stream. Any HW Generating Activity will coordinate waste generation with 27 SOCES/CEIE to ensure that waste streams are properly characterized as required by applicable federal, state, DoD and AF directives. In support of requirements, the Generating Activity will:

Provide access to appropriate facilities, shops, and equipment for Environmental Element (and authorized representatives) and authorized state, federal, and AF inspectors and assessors.

Ensure shop-level EESOH-MIS accounts accurately reflect the materials needed for successful mission accomplishment.

4.3.1 Supervisors of Hazardous Waste Generating Activities –

The Supervisors of HW-generating activities will:

Designate in writing to 27 SOCES/CEIE primary and alternate HW Monitors for each IAP/SAA or generating shop.

Attend HW training if personnel they supervise generate HW.

Ensure that all personnel who work with HW receive and successfully complete annual HW training either through Environmental Element instructor-based training, or virtual training module available on eDASH.

Additionally, supervisors will examine employee training to ensure that adequate site and task-specific familiarization is accomplished, and supplemented with on-the-job training, as needed. HW generators must retain personnel training records and those of former employees in accordance with AF Records Disposition Schedule.

Supervisors must ensure records of HW training are on-site and available for inspection and that recordkeeping requirements under 40 CFR Part 262, Subpart A or 40 CFR Part 265, Subpart B are met.

Originals of these records may be kept by AF Form 1098, Special Task Certification and Recurring Training; AF Form 55, Employee Safety and Health Record; installation centralized training records;

computer database; or letters/certificates of completion. At a minimum, supervisors will ensure training records include the student’s name, job title, job description, previous HW training, dates of training, instructor’s name (or functional area), test score (if applicable), and date of annual refresher course.

4.3.2 Primary and Alternate Hazardous Waste Monitors –

Manage the IAP in compliance with applicable laws, regulations and this HWMP.

- Ensures each IAP displays a posted sign identifying the location as an IAP.

- As required, ensures inspections of IAPs are completed, and that containers are in good condition.

- Ensures IAP containers are kept closed except to add waste.

- Ensures each IAP container is properly labeled in accordance with the HWMP with the contents of the container and the words “Hazardous Waste.”

Maintains a Hazardous/Universal Waste Continuity Binder to retain all records required in support of the work center’s HW program as required by this Plan, to include the following:

- A current Waste Stream Analysis, based on material authorizations in EESOH-MIS.

- Current Waste Process Descriptions, as applicable.

- Current DLA Form 2511 (HWPS) or electronically generated equivalent.

- Training records (See Section 6.0, Recordkeeping and Reporting).

- HW Monitor Appointment Letters, both active and inactive, for three (3) years past the term of employment.

- Records of initial and annual HW training, both active and inactive, for three (3) years.

- Container logs showing retrieval of all HW containers from shop IAP, for three (3) years.

- AF Forms 2005 (or electronic equivalent generated through EESOH-MIS) showing receipt of containers by HWAS personnel for three (3) years.

- Maintains a hard copy of the HWMP or access to an electronic copy of the HWMP.

Maintain adequate emergency spill response capability and personal protective equipment appropriate to the section’s IAP.

Support the Cannon AFB Waste Minimization Program.

Contact the HW Program Manager about any hazardous/universal waste-related concerns.

Supervise/train section workers involved in the generation and handling of hazardous and universal wastes.

As necessary, functions as the primary focal point for First Responders on information regarding the presence of HW in shop-specific work areas.

Coordinates with the HW Program Manager for the development of the shop-specific Waste Stream

Analysis and Waste Process Descriptions, as applicable.

4.3.3 Proponents of Local Contracts –

Installation proponents of construction/demolition, renovation, cleanup, or other local contracts, will include proper waste handling, labeling and disposal as part of the contract requirements. HW generated from contracted cleanup or remediation projects or construction or demolition and renovation contracts will not be disposed through the DLA-DS without prior coordination with and approval of the HW Program Manager. HW being considered for recycling is mandated to meet requirements set forth in 40 CFR Part 261.6, Requirements for Recyclable Materials. Hazardous material being recycled or reclaimed in accordance with 40 CFR Part 261, is not considered disposal. If hazardous material has been abandoned or discarded, the fact that recycling is occurring does not prevent the need to characterize the material leaving the base.

4.4 Air Force Civil Engineer Center (AFCEC), Environmental Directorate (AFCEC/CZ) –

AFCEC/CZ, a Primary Subordinate Unit to the Air Force Installation Mission Support Center (AFIMSC), provides execution support to installations in order to implement this plan, consisting of subject matter expertise, issuing supplemental guidance, allocating resources, and overseeing execution of the environmental management process throughout the AF. The AFCEC/CZ, will:

Provide SMEs to serve as AF-wide authoritative experts for each major Environmental Compliance Program, establishing and updating procedures, tracking and analyzing overall environmental compliance, and developing enterprise-level compliance strategies and continuous improvement initiatives.

Assist in the collection, quality assurance, and analysis of HW compliance data consistent with AFI 32-7001 requirements.

Develop AF-wide environmental compliance and resource management education and training.

Cross-feed best practices and standardized Environmental Compliance programs across the AF.

Plan, program, and budget environmental compliance requirements for applicable programs described in this plan in accordance with AFI 32-7001.

Validate enforcement actions or notices of violations, and tracks until closure, in accordance with

AFI 32-7001. As stated in AFI 32-7001, SMEs review management action plans to ensure outstanding open enforcement actions are resolved within the required time frames; review the response to regulatory agency inspection findings to ensure process owners take timely corrective actions and implement appropriate preventive measures; and ensure reporting timelines outlined in AFI 32-7001 are followed.

Review all permits, permitting requirements, and associated federal, state, local RCRA regulations (40 CFR Parts 239-282), for waste management compliance, to ensure compliance conditions are met for both current mission operations and projected mission growth.

Consult with Environmental Planners and 27 SOCES/CEN on waste management impacts as early as practicable to ensure timely EIAP assessments under the National Environmental Policy Act (NEPA, 40 CFR Parts 1500-1508, Council on Environmental Quality) process for Military Construction (MILCON) and non-MILCON projects.

Ensure coordination through the appropriate chain-of-command of any comments on federal, state, and local proposed rulemaking, revisions, plans, protocols, and permits.

Track, assess, and report new or emerging regulatory requirements for potential impact on installation operations. Ensures any such requirements are incorporated into appropriate program elements and reports identified impacts through the chain of command.

Establish a Hazardous Material Data Steward for EESOH-MIS to centrally create and manage Safety Data Sheets and associated product hazard data for EESOH-MIS and to be in a position to transfer SDS information to the AF SDS Focal Point in accordance with AFI 90-821, Hazard Communication (HAZCOM) Program.

Serve as the single, AF-wide authoritative expert for installation HW compliance, and waste minimization.

Serve as a focal point for environmental regulatory expertise and information related to toxic areas, including Polychlorinated Biphenyls (PCB), Emergency Planning and Community Right-to-Know Act (EPCRA), and Toxic Substances Control Act (TSCA).

4.5 DLA-Dispositions Services (DLA-DS) –

Cannon AFB will use DLA-DS as the DoD HW disposal agent for routinely generated HW, or HW from base operations not connected to a specific contract, in accordance with DoDM 4160.21.

4.6 Bioenvironmental Engineer (27 SOOMRS/SGPB) –

Ensures the HWMP is carried out in accordance with Air Force Occupation Safety and Health standards and current medical regulations.

Provides guidance for appropriate personal protective equipment (PPE) and cleanup of spills.

Serves as primary OPR for the disposal of radioactive wastes.

4.7 Contracting Officer (27 SOCONS/LGC) –

Ensures that the Staff Judge Advocate and DLA-DS review all local HW disposal contracts.

Ensures all contract specifications require that any contractor-generated waste is the responsibility of the contractor and will be managed as required by federal and state regulations.

5.0 TRAINING

HW training is required by law. All training requirements and sources are provided in the Environmental Training Matrix on eDASH. Specific local training procedures are provided in section 5.1.

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

HW Program Managers and alternates appointed in writing by the Wing Commander to sign manifests, require specific training to include HW Management Compliance Training and DOT training to sign HW manifests. Installation HW Program Managers should complete the following in-residence courses (or equivalent): Air Force Institute of Technology (AFIT) 521, HW Management; and DLA - DCPSO00510, Transportation of Hazardous Material/ HW (Interservice Environmental Education Review Board [ISEERB] approved). After initial course completion, refresher training is required annually for RCRA, and every 3-years for the DOT course. See training matrix for more information.

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

Installation Supplement – Training

5.1 Training –

Effective training will help personnel avoid common compliance problems associated with 27 SOW HW operations.

Training is available through an instructor-based course that 27 SOCES/CEIE offers once per quarter.

Contact the HW Program Manager for the current training schedule. Instructor-based training is recommended for HW handlers newly assigned to HW management responsibilities.

Current web-based training is available on eDASH or by DVD check-out and may be used to satisfy regulatory requirements.

5.2 Initial Training –

IAW AFMAN 32-7002, all personnel who work with HW and their supervisors must receive and successfully complete HW training within six months of appointment. Personnel must work under the supervision of a trained person until they have received training.

Upon completion, personnel will receive a certificate to document training. For those appointed as Hazardous/Universal Waste Monitors, proof of training must be filed in the Hazardous/Universal Waste Continuity Binder.

5.3 Annual Training –

All personnel whose duties include working with HW, and the supervisor of the waste generating activity, must complete annual HW training. The intervals between training must not exceed one year. Contact the HW Program Manager if more information about initial or annual training is needed.

5.4 Hazardous Waste Accumulation Site Personnel Training –

Cannon AFB HWAS personnel, whether military, civilian or contractor, shall ensure the required HW training and student/employee competency is accomplished for all personnel whose activities affect compliance at the HWAS before commencing these duties. 40 CFR 265.16 requires initial training, annual refresher training, and specific training records for personnel who manage t h e HWAS.

The HWAS Manager is responsible for competency training of HWAS personnel on the topics listed below:

HW characterization Site-specific contingency plan and its implementation LQG regulatory requirements that apply to accumulating wastes for 90 days Universal waste regulations Land Disposal Requirements (LDR) regulations that apply to LQG Recordkeeping requirements, including those related waste characterization, manifesting, LDR requirements, and training DOT regulations applicable to individuals’ job duties

Initial and annual refresher training should assist Cannon AFB HWAS Managers in maintaining proficiency in these topics. All topics need not be covered in each annual refresher as regulations associated with the topics do not change each year. Cannon AFB HWAS Managers must also receive DOT training relevant to the pre-transport operations they perform at least once every three years.

5.5 HW Program Manager Training –

The HW Program Manager oversees all HW management on base and maintains documentation of legally required training in the 27 SOCES/CEIE files for regulatory review. The HW Program Manager will also be familiar with the following topics:

HW characterization Site-specific contingency plan and its implementation LQG regulatory requirements that apply to accumulating wastes for 90 days Universal waste regulations LDR regulations that apply to LQG Recordkeeping requirements, including those related waste characterization;

manifesting, LDR requirements, training, etc.

DOT regulations applicable to individuals’ job duties

Annual HW courses from a variety of commercial and AF sources can be used to keep current on laws and regulations regarding HW. The HW Program Manager will also receive DOT training at least once every three years.

5.6 Training Recordkeeping –

Training records for personnel working at the Cannon AFB HWAS must include the following:

Job title for each position at the facility related to HW management and the name of the employee(s) filling each job.

A written job description for each position;.

A written description of the type and amount of both introductory and continuing training that will be given to each person fulfilling each position.

Records that document the required training or job experience has been completed.

Training records on current employees and records for former employees must be kept for three years from the last day of employment at the shop.

Personnel must retain a copy of their original proof of training and provide a current copy of the training records to the HW Program Manager in 27 SOCES/CEIE within 10 business days after course completion.

These records must be accessible for inspectors, assessors, and/or auditors to review (e.g., EPA, NMED HWB, and ESOHCAMP auditors, etc.).

6.0 RECORDKEEPING AND REPORTING

Recordkeeping

The installation complies with the following U.S. Federal HW recordkeeping requirements as applicable based on generator status. NOTE: Retention time is defined by regulation as onsite and readily accessible for inspections and/or reference; after retention, the record(s) follow applicable Air Force Records Management rules

Summary of HW Recordkeeping Requirements

Record* Citation Retention Time** Citation HW determination documentation

40 CFR 262.11(f) 3 years from the date that the waste was last sent to a TSDF

40 CFR 262.11(f)

HW Biennial/Annual Report

40 CFR 262.41 3 years from the due date of the report 40 CFR 262.40(b)

HW manifest (electronic or paper)

40 CFR 262.20 3 years from the day the waste was accepted by the initial transporter

40 CFR 262.40(a)

Small Qty HWAS inspection logs

40 CFR

262.16(b)(2)(iv)

Although records are not formally required, the best management practice is to record and retain for 3 years to demonstrate compliance

N/A

Large Qty HWAS inspection logs

40 CFR

262.17(a)(1)(v) 40 CFR 264.15(d) 40 CFR 265.15(d)

For interim and permitted operations, 3 years from the date the inspection was conducted.

For all other LQGs, the best management practice is to retain for 3 years to demonstrate compliance

40 CFR 265.14(d) 40 CFR 265.15(d)

Preparedness and prevention arrangements with local authorities

40 CFR

262.16(b)(8)(vi)(B)

The federal regulations do not offer a minimum retention time, but the best management practice is to retain the plan while active and for 3 years thereafter to demonstrate compliance

N/A

Consolidation of HW received from very small quantity generators.

40 CFR 262.17(f) 3 years from the date the HW was received from the very small quantity generator

40 CFR 262.17(f)

Exception reports 40 CFR 262.42 3 years from the due date of the report 40 CFR 262.40(b)

Land restricted waste determination

40 CFR 268.7(a)(1) 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(a)(8)

Land restriction notice and certification

40 CFR 268.7(a)(2) 3 years from the date the waste was last sent to a TSDF

40 CFR 268.7(a)(8)

Notification of intent to export waste

40 CFR 262.83(b) 3 years from the date the HW was accepted by the initial transporter

40 CFR

262.83(i)(1)(i)

Waste export confirmation of receipt and exception reports

40 CFR 262.83(h) 3 years from the date the HW was accepted by the initial transporter

40 CFR

262.83(i)(1)(iii)

Annual report (required of primary exporters of HW)

40 CFR 262.83(g) 3 years from the date the HW was accepted by the initial transporter

40 CFR

262.83(i)(1)(ii)

Employee training records (including appointment letters for key HW

40 CFR

262.16(b)(9)(iii)

40 CFR

For interim and permitted operations- current personnel: until closure of the site; Former personnel: 3 years from date the individual

40 CFR

262.17(a)(7)(iv) 40 CFR 264.16(e)

Record* Citation Retention Time** Citation personnel) 262.17(a)(7)(iv)

40 CFR 264.16(d) 40 CFR 265.16(d) last worked there. For all other LQGs and SQGs, the best management practice is to retain for 3 years to demonstrate compliance

40 CFR 265.16(e)

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

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.

Installation Supplement – Recordkeeping and Reporting

6.1 Recordkeeping –

Where applicable, facility permits are the responsibility of the Installation Commander. Cannon AFB will track HW with the EPA HW manifest and will report HW management activities using EESOH-MIS.

These records are either maintained in the files at 27 SOCES/CEIE or at the Cannon AFB HWAS. The HW Program Manager maintains the HWMP, which includes a table documenting the location of each type of record.

6.2 Training Recordkeeping –

Training records of current personnel must be kept until the closure of the site.

Training records of former personnel must be kept for 3 years from the date the individual last worked at Cannon AFB.

6.3 Waste Determination Records –

At Cannon AFB, waste determination records include the following:

Solid Waste Analysis Waste Process Descriptions, if applicable SDSs (or EESOH-MIS reports), if applicable Analytical results including the chain-of-custody documents, Quality Assurance/Quality Control

(QA/QC) laboratory information, if applicable HWPS, if applicable

The HW Program Manager and Cannon AFB HWAS personnel jointly maintain files organized by shop code and waste stream. Files include the information identified above as the waste determination record.

HW Monitor maintain copies of waste stream analyses, waste process descriptions and hazardous (and/or universal) waste profile sheets and associated analytical results; SDSs used as basis for waste determinations will be maintained by 27 SOCES/CEIE. SDSs are retained as the basis for waste determination for unused, discarded products. Chain-of-custody documents and laboratory QA/QC data are maintained with the analytical records.

A suggested template for the organization of a section Hazardous/Universal Waste Continuity Binder may be found on eDASH.

6.4 Reporting to NMED –

6.4.1 Hazardous Waste Reporting –

RCRA requires HW generators and permitted facilities to submit specific reports regarding the types and quantity of wastes generated, environmental releases, and manifest irregularities. The HW Program Manager shall oversee the submittal and maintenance of the records and shall make them available to appropriate state and federal inspectors upon request.

6.4.2 Annual Hazardous Waste Fee Report –

Cannon AFB and Melrose AFR pay HW generation fees to NMED annually. This report must be submitted to NMED no later than August 1 for the previous calendar year. These annual fees are intended to meet necessary expenses in the administration and operation of the state HW program. HW fees are calculated on a per pound basis. In addition, Cannon AFB is required to pay a set annual business fee based on its status as a LQG.

6.4.3 Biennial Hazardous Waste Report –

Cannon AFB ships HW off-site to a TSDF facility within the United States and, therefore, must prepare and submit a Biennial Report to NMED by March 1 of each even-numbered year IAW 40 CFR 262.41.

This report includes:

Completed EPA Form 8700-12, RCRA Site Identification form The EPA identification number Name and address of the generator The calendar years covered by the report The EPA identification number of each transporter used The EPA HW number The DOT hazard class The quantity of HW shipped off-site A description of the efforts undertaken by Cannon AFB during the year to reduce the volume and toxicity of waste generated A description of any changes in volume and toxicity of waste compared to previous years

6.5 Manifests –

The HW manifest tracks HW from the facility that generated the waste to TSDFs. The “cradle-to-grave” manifest ensures accountability for the waste shipment and verification that the appropriate TSDF received

it. IAW 40 CFR 262.23, the generator must sign the manifest certification and obtain one copy of the handwritten signature of the initial transporter, the DLA-DS contractor, and the date the HW transporter accepted the waste. The DLA-DS contractor cosigns all HW and PCB manifests for waste sent through them for disposal. The Cannon AFB Installation Commander (IC) designates individuals authorized to sign the manifest in writing. DLA-DS and 27 SOCES/CEIE each keep one copy of the manifest until a signed copy is received from the TSDF.

When the shipment arrives at the TSDF, the TSDF signs the manifest confirming receipt of the waste. The TSDF sends one copy of the signed manifest to DLA-DS. The DLA-DS contractor will then forward a copy to 27 SOCES/CEIE.

6.6 Exception Report -

IAW 40 CFR 262.42, if the base does not receive a copy of the manifest signed by the TSDF within 40 days from the date the transporter accepted the waste for shipment, DLA-DS must contact the transporter and/or TSDF to determine the status of the HW. An exception report must be submitted to NMED HWB if the base does not receive a copy of the manifest signed by the TSDF within 45 days of the date that the initial waste transporter accepted the waste. The HW Program Manager prepares the exception report, if required, and maintains copies of the exception reports in the 27 SOCES/CEIE files.

6.7 Notification and Certification –

If a waste does not meet the treatment standards in 40 CFR 268 Subpart D, the generator must send one-time written notice, at a minimum, to each TSDF receiving the waste. A copy of this notice must be retained in the HW Program files. Be aware that the state receiving the waste may impose additional requirements.

A new notification is required whenever the waste profile or treatment facility changes.

When a new waste stream is identified for shipment or an existing waste stream has changed, Cannon AFB provides the vendor with a copy of the waste profile data, including the LDR determination, for each waste stream so that LDR notifications may be completed. Cannon AFB personnel will review the LDR forms, which the vendor drafts based on the waste profile information provided to ensure that the requirements of 40 CFR 268 are met. These requirements may include the following:

The notice for restricted waste not meeting applicable treatment standards includes all information required by Generator Paperwork Requirements Table in 40 CFR 268.7(a)(4).

If the waste meets the treatment standard for land disposal, a certification drafted as specified in 40 CFR 268.7(a)(3)(i) is provided to the vendor.

LDR notices for lab packs provide either information specified in the Generator Paperwork Requirements Table or, if the alternate treatment standard for lab packs is used, Cannon AFB complies with the requirements in 40 CFR 268.7(a)(9), including certifying that wastes in Appendix IV of 40 CFR 268 are not present.

Although it is unlikely that a case-by-case extension under 40 CFR 268.5 or a petition to allow land disposal of prohibited waste will be required, Cannon AFB personnel will ensure compliance with 40 CFR 268.7(a)(4) if these exceptions are used.

Comments on vendor-prepared LDR notices are usually provided to the vendor prior to the day of shipment so that the LDR forms can be revised, as necessary. All notifications and certifications are prepared and maintained per 40 CFR 268.7. On the day of shipment, Cannon AFB personnel will perform a final review of the LDR notifications and obtain copies of the notifications to include with the manifest in the facility’s file.

6.8 Wastes Shipped to RCRA Subtitle C Facilities –

Cannon AFB follows the notification and recordkeeping requirements when wastes are shipped off-site to permitted RCRA Subtitle C facilities.

6.9 Waste Generation Records –

The HWAS personnel shall provide the HW Program Manager with the waste generation quantities no later than the first Monday of the month for the prior month. The waste generation quantities, in pounds, are available in EESOH-MIS.

6.10 Documentation of Recycling Activities –

Cannon AFB personnel ship certain commodities, such as spent antifreeze and used oil, off-site for recovery. 27 SOCES/CEIE maintains information about the vendors who recycle wastes that are potentially HW. In addition, records of waste analyses that document the classification of wastes shipped off-site for recycling are maintained in 27 SOCES/CEIE records. If a waste is exempt from HW management because of a regulatory exclusion based on recycling, the Solid Waste Program Manager will maintain records pertaining to the generation, off-site recycling, demonstration that the waste was not speculatively accumulated, and information the vendor provides regarding the recycling process.

6.11 Hazardous Waste Monitor Recordkeeping –

HW Monitors must maintain a Hazardous/Universal Waste Continuity Binder that includes the following information:

Signed appointment letters for the HW Monitors, which must be updated as personnel change.

Training Records.

Hazardous Materials Waste Stream Analysis (or Solid Waste Determination) that outlines appropriate disposal based on each product used.

Waste stream characterization information for all processes and applicable forms, including the

HWPS, Waste Process Descriptions, and any document revisions.

For HW, AF Forms 2005 (or electronic equivalent generated through EESOH-MIS) and container log.

Copies of waste program evaluations, which may consist of, but not limited to, SAV results, Unit

Environmental Coordinator (UEC) guidance, Environmental, Safety and Occupational Health Compliance Assessment Management Program (ESOHCAMP) assessment findings with corrective actions, and notice of deficiencies or violations issued by either EPA Region VI or the State of New Mexico.

7.0 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:

Log into EESOH-MIS, select the “Reporting” option, and select “Hazardous Waste” to generate the Waste Site Waste Stream Summary Report.

The resulting waste inventory report can be placed into Appendix B, Hazardous Waste Streams/Profiles.

Installation Supplement – Waste Inventory

The HW Stream Inventory identifies waste streams and their EPA waste codes that have been characterized at Cannon AFB (see Appendix A). Because of the dynamic mission at Cannon AFB, potential exists for the HW Stream Inventory to change day-to-day. The current, updated Waste Stream Inventory and location of each waste stream should be maintained on eDASH in the HW Program area.

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

Log into EESOH-MIS, select the “Reporting” option, and select “Hazardous Waste” to generate the Waste Site Waste Stream Summary Report.

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 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 WAP found in Appendix B.

The WAP details the wastes that have been evaluated and analyzed, a description of the testing and…