KAFB HWMP.pdf

Template Version October 2018

U. S. AIR FORCE

HAZARDOUS WASTE MANAGEMENT PLAN

Kirtland Air Force Base

9/19/2022

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

1.1 Overview

1.2 Scope

1.3 Objective

1.4 Goals

2.0 INSTALLATION PROFILE

3.0 ENVIRONMENTAL MANAGEMENT SYSTEM

4.0 ROLES AND RESPONSIBILITIES

4.1 Wing Commander (377 Air Base Wing Office of the Commander)

4.2 Environmental Safety and Occupational Health Council (ESOHC)

4.3 Civil Engineer - Environmental Compliance Section (377 MSG/CEIEC)

4.4 Base Safety (377 ABW/SE) and Fire Safety (377 MSG/CEF)

4.5 Bioenvironmental Engineering (377 OMRS/SGXB)

4.6 Hazardous Material Emergency Planning and Response Team

4.7 Defense Logistics Agency Disposition Services (DLA-DS)

4.8 Judge Advocate, Environment and Real Property (377 ABW/JA)

4.9 Installation Contracting Offices

4.10 Generating Organizations

4.10.1 Unit Environmental Coordinators

4.10.2 Initial Accumulation Point (IAP) Supervisors/Managers

4.11 Hazardous Waste Accumulation Site (HWAS) Contract Support

5.0 TRAINING

5.5 Personnel Requiring Training

5.5.1 Kirtland-specific HW Training

6.0 RECORDKEEPING AND REPORTING

6.1 Waste Collection Site (WCS) Logbook

6.2 Training Documentation

6.3 Inspection Documentation

6.4 Required Documentation for HWAS Support Contractors

7.0 PROCEDURES

7.1 Waste Inventory

7.2 Waste Identification

7.2.1 Process Descriptions

7.2.2 Waste Analysis Plan

7.3 Container Management

7.3.1 Container Requirements

7.3.2 Obtaining Containers

7.3.3 Adding Waste to Containers

7.3.4 Container Storage and Handling

7.3.5 Container Weights

7.3.6 Review of Waste Containers

7.4. Labeling and Marking

7.4.1 Waste Containers

7.4.2 Accumulation Start Date (ASD)

7.4.3 Wastes Pending Analysis

7.5 Accumulation Area Management

7.5.1 Waste Collection Sites (WCS)/ Initial Accumulation Points (IAPs)

7.5.1.1 Establishing a Collection Site

7.5.1.2 Temporary Deactivation of a Waste Collection Site

7.5.1.3 Closure of a Waste Collection Site

7.5.1.4 Relocation of Waste Generating Processes

7.5.2 Less Than 90-Day Accumulation Areas

7.6 Transportation

7.7 Turn In/Disposal

7.7.1 Full Waste Containers

7.7.2 Unknown and Abandoned Waste

7.7.3 Periodic or One Time Turn-Ins

7.7.4 TDY or Contractor-Generated HW

7.7.5 Excess Hazardous Materials

7.8 Inspection

7.8.1 Internal Inspections

7.8.2 External Inspections

7.9 Waste Minimization/HW Recycling

7.9.1 Excess Hazardous Material Free-Issue Program

7.9.2 Pollution Prevention and Source Reduction

7.9.3 Off-Site Treatment Facilities

7.10 Preparedness and Prevention

7.10.1 Spill and Contingency Plans

7.10.2 Spill Response and Reporting

7.11 Waste Specific Procedures

7.11.1 Used Oil Management

7.11.2 Universal Waste (UW) Management

7.11.2.1 UW Lamps

7.11.2.2 UW Batteries

7.11.3 Aerosols

7.11.4 Off-Specification Fuels

7.11.5 Empty Hazardous Materials Containers

8.0 REFERENCES

9.0 ACRONYMS

10.0 DEFINITIONS

11.0 INSTALLATION-SPECIFIC CONTENT

APPENDICES

Appendix A – Waste Analysis Plan

Appendix B– Hazardous Waste Streams/Profiles

Appendix C– Hazardous Waste Training Plan

Appendix D– Inspection Forms

Appendix D1: HW Accumulation Point Weekly Inspection Checklist

Appendix D2: UEC’s Quarterly IAP Inspection Checklist

Appendix E: Waste Collection Site (WCS) Logbook Table of Contents

Appendix F: Waste Characterization Process Description

Appendix G: Sample Collection & Analysis Request Form

Appendix H: Waste Segregation Log

Appendix I: Container Tracking Log

Appendix J: Initial Accumulation Point, Universal Waste Site, & Waste Collection Site

Designation Sign

Appendix K: Air Force Form 2005, Issue/Turn-in Receipt

Appendix L: Excess Hazardous Material Inventory Form

Appendix M: Site-Specific Contingency Plan Template

Appendix N: Spill Response Procedures

Appendix O: Spill Response Reporting Form

Appendix P: Laboratory Analysis Tracking Log

Appendix Q: IAP Manager Appointment Letter

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: When installations update their HWMPs, they should refer to the AF EMP Repository on eDASH to ensure the most current version is applied. Installations are not required to change HWMPs after template updates.

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 or readiness format or coordination requirements of

AFI 10-401, Air Force Operations Planning and Execution. It is governed by AFMAN 32-7002, Environmental Compliance and Pollution Prevention, Section 5.2. Hazardous Waste Management Plan

(HWMP). Because this is not a contingency plan, coordination should be with 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:

0 Initial Plan 4/1/2015 Mr. John Pike, 377 MSG/CEI

1 Conformance to AFCEC required template; updated due to changes in NMED policy

9/10/2018 Richard W. Gibbs, Colonel, USAF, Commander, 377th Air Base Wing

2 Administrative 9/6/2019 Mr. Joseph Pellish, EMS CFT Chair

3 Administrative 9/3/2020 Mr. Joseph Pellish, EMS CFT Chair

4 Administrative 9/1/2021 Mr. Joseph Pellish, EMS CFT Chair

5 Administrative 9/19/2022 Mr. Andrew Verdi

EMS CFT Chair

Record of Annual Review – IAW AFMAN 32-7002, this plan is reviewed annually by the EMS CFT.

Formatting and administrative changes should be noted in the previous paragraph for record of updates as approved by the EMS CFT Chair and do not require Installation Commander or Environmental, Safety, and

Occupational Health Council (ESOHC) approval. Substantive revisions require coordination and approval by the Installation Commander as determined by the EMS CFT Chair and/or IAW host installation procedures. Substantive changes include manpower or resource requirements changes that impact installation hazardous waste generating organizations.

Record of EMS CFT Annual Review

Review Date EMS CFT Chair Notes/Remarks

9/6/2019 Mr. Joseph Pellish Approved by Chair and EMS CFT

9/3/2020 Mr. Joseph Pellish Approved by Chair and EMS CFT

9/1/2021 Mr. Joseph Pellish Approved by Chair and EMS CFT

9/19/2022 Mr. Andrew Verdi Approved by Chair and EMS CFT

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

1.1 Overview

The federal HW management system originated with the Resource Conservation and Recovery Act

(RCRA) of 1976. Regulations published by the EPA establish requirements for a “cradle-to-grave” HW management system. Under this system, the generator of HW is ultimately responsible for HW from the moment of generation until the waste is no longer hazardous or is properly disposed of and/or treated.

Current USAF policy regarding the management of HW, as outlined in AFMAN 32-7002, Environmental

Compliance and Pollution Prevention, is that generation of HW will be minimized to the greatest extent possible and that which is generated will be reused or recycled whenever feasible. When reuse or recycling is not feasible, HW will be managed and disposed of in full compliance with all applicable laws and regulations. KAFB generates a variety of waste throughout the base. The management of this waste must comply with all applicable State and Federal laws and regulations and DoD, USAF, and Air Force

Global Strike Command (AFGSC) policy. Regulations and policy are in place to enforce responsible management of HW.

The 377th Mission Support Group, Civil Engineer Division, Installation Management Branch, Environmental Compliance Section (377 MSG/CEIEC) is responsible for implementing the overall HW management program at KAFB, including the following areas:

• Waste characterization;

• Establishing collection sites;

• Receiving and processing HW for turn-in;

• Reporting, tracking logs, and manifesting;

• Spill reporting;

• Regulatory Interface;

• Recordkeeping; and,

• Hosting/conducting inspections.

1.2 Scope

This HWMP provides guidance for all 377th Air Base Wing (ABW) and mission partners that generate

HW regarding appropriate storage, handling and disposition. There are no exceptions for Air Force units, tenants, contractors, vendors or suppliers operating on base. The only exceptions are for those entities falling under the Department of Energy (DOE)(to include Sandia National Laboratory (SNL), and associated contractors operating independently of DoD and Air Force directives and control), and for construction contractors operating under a current and valid contract issued by a government contracting agency. All other 377 ABW units and reimbursable tenants may be held responsible for fines resulting from noncompliance, and individuals found responsible of willful negligence may face legal action commensurate to the offense.

KAFB organizations (host and tenants) employing contractors that deal with HW will task their contractors to comply with this HWMP and all applicable federal, state, and USAF regulations.

This HWMP is not intended to cover all incident response or emergency responsibilities and requirements addressed in the Spill Prevention Control and Countermeasure (SPCC) Plan or the Installation Emergency

Management Plan (IEMP).

To comply with the Federal Facility Compliance Act (FFCA), KAFB must manage its waste in accordance with (IAW) RCRA, as amended by the Hazardous and Solid Waste Amendment of 1984

(HSWA).

Additionally, this HWMP does not address Environmental Restoration Program (ERP) waste. Please refer to the Investigative Derived Waste Plan (IDWP) for details on the HW management protocol for these wastes. The IDWP can be found on the KAFB eDASH website.

1.3 Objective

The objective of the HWMP is to facilitate the responsible management of HW at KAFB, and to provide guidance to all host-base and tenant personnel who generate and handle HW. This HWMP prescribes responsibilities, policies, and procedures for managing HW at KAFB. All relevant installation HWMP documents can be found on the KAFB eDASH website. Tenant organizations without access to eDASH can request these documents by contacting 377 MSG/CEIE.

1.4 Goals

In accordance with the KAFB Environmental Management System (EMS) Environmental Commitment

Statement, the goals of the HW program are as follows:

• Conduct all HW management activities in a manner that will protect the environment, human health, and the welfare of base personnel and the surrounding communities;

• Comply fully with all applicable laws, regulations and directives governing HW management;

• Provide an overall framework for management of HW by tenant organizations on KAFB;

• Reduce the volume and/or toxicity of HW through source reduction to the maximum extent possible; and,

• Reuse/recycle wastes where possible and practicable.

2.0 INSTALLATION PROFILE

Installation Profile

Scope of Plan All KAFB host and tenant organizations and contractors except for DOE, SNL, and their associated contractors, who are responsible for HW under a separate EPA ID number

OPR (Civil Engineer or other designated office)

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

HW Program Manager HW Program; 846-0003, kirtlandhazwaste@us.af.mil

Alternate HW Program Manager HW Program; 846-0003, kirtlandhazwaste@us.af.mil

Emergency contacts For emergencies, personnel should call 911 or 853-9111 from a cell phone. When calling 911, the fire equipment dispatcher and security forces dispatcher will pick up the line

Waste registration numbers EPA ID #: NM9570024423

HW generator status Large Quantity Generator

KAFB does not hold a treatment, storage, and disposal facility (TSDF) permit.

Universal waste handler status Small Quantity Generator

Permitted HW operations Large Quantity Generator

Federal regulatory references − 40 CFR Parts 260-266, and 268 for the regulation of

HW

− 40 CFR Part 273 for the regulation of UW

− 40 CFR Part 279 for the regulation of used oil

− Federal DOT Regulations 49 CFR Parts 171 through

180 regarding HM transportation

− OSHA Regulation 29 CFR Part 1910 regarding employee safety

− FFCA of 1992

State and local regulatory agencies New Mexico Environment Department (NMED)

State and local regulatory references − New Mexico Hazardous Waste Act, as amended in 1981

− New Mexico HW management regulations, under New

Mexico Administrative Code as amended, Title 20, Chapter 4, Part 1

DLA-DS area office and/or approved

HW disposal contractors

DLA-DS, Tucson AZ

HW accumulation sites The KAFB Less than ninety day (<90 day) Hazardous

Waste Accumulation Site (HWAS) is located in Building

HW accumulation time limits Less than ninety (<90) days

HW generator reporting frequency Biennial

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) 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 (DLA) Disposition Services

• 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

The following sections detail responsibilities for activities associated with the generation and management of HW on KAFB. Ultimately, waste generators (host and tenant organizations and on-base contractors) bear the responsibility for ensuring HW management functions are conducted in full compliance with this HWMP. Even though numerous individual generating activities are performed at

KAFB, the base as a whole is considered as one large-quantity HW generator (LQG) for regulatory purposes. (See section 10.0 for definitions)

4.1 Wing Commander (377 Air Base Wing Office of the Commander)

The Wing Commander of the 377 Air Base Wing (377 ABW/CC) has the following responsibilities:

• Ensure the installation, as a potential generator of hazardous waste, establishes a hazardous waste program IAW AFPD 32-70 to ensure compliance with Chapter 5 of AFMAN 32-7002 and all applicable federal, state, and local laws and regulations;

• Ensure compliance with RCRA permit requirements/conditions if the installation owns a permit for HW treatment, storage, and disposal facilities. In the event of a conflict, permit requirements supersede the requirements in AFMAN 32-7002. Installations minimize dependence on RCRA permits through waste minimization efforts or use of alternate closed loop treatment if feasible;

• Ensure the installation accomplishes appropriate management and disposal of military munitions or material potentially presenting an explosive hazard IAW the requirements in AFMAN 32-

7002;

• Ensure that appropriate HW management practices, consistent with applicable requirements, are emphasized to all installation personnel through education and training, to include shop-level training and this HWMP;

• Ensure that the HWMP is applicable and followed by all installation personnel to include tenants and contractors;

• Ensure that a HW minimization program is in place to reduce the volume and toxicity of waste generated and ensure that HMs are made available for reuse to the maximum extent possible before disposal;

• Ensure that enforcement actions are addressed within stated time frames;

• Ensure that employees handling HW have HW responsibilities reflected in their job descriptions or Significant Additional Duty(s) section of job description as applicable;

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

• Delegate signature authority for HW manifests. IAW AFMAN 32-7002, signature authority for waste managed under 40 CFR §262 shall remain with qualified, trained DoD employees. IAW

AFI 32-7020, authority for ERP-generated wastes shall be delegated to AFCEC/CZO.

• Ensure that the legal office and Civil Engineer (CE) coordinate on any permits, land use restrictions, or other binding agreements with regulatory agencies.

• Publish the installation’s EMS Commitment Statement. This statement can be found on the

KAFB eDASH website under EMS.

4.2 Environmental Safety and Occupational Health Council (ESOHC)

The ESOHC will annually review and approve installation HWMP, and review programs, monitor progress, and advise leadership (refer to AFI 90-801, Environment, Safety, and Occupational Health

Councils for further guidance).

4.3 Civil Engineer - Environmental Compliance Section (377 MSG/CEIEC)

The 377 MSG/CEIEC has the following responsibilities:

• Act as the liaison office for environmental compliance (hazardous waste) issues with regulatory agencies, IAW applicable policy;

• Establish procedures, provide technical content for management plans, and provide technical expertise regarding waste management requirements. Plans and procedures can be found on the

KAFB eDASH website;

• Coordinate with AFCEC/CZ to ensure proper programming and ensure proper recordkeeping procedures. Maintain all HW related records IAW RCRA and USAF requirements;

• Implement procedures to ensure generators maintain up-to-date waste information and profiles, to include implementing the USAF-approved automated HW tracking system;

• Sign HW manifests for installation-generated HW, as delegated by the Installation Commander;

• Ensure the proper disposal of RCRA-regulated wastes from the installation;

• Ensure that local training is provided to organizations generating HW, and

• Annually reviews this HWMP for currency, ensures plan is presented for annual approval by the

ESOHC, and publishes changes or revisions, as required.

4.4 Base Safety (377 ABW/SE) and Fire Safety (377 MSG/CEF)

Base Safety and Fire Safety will ensure all HW management plans and procedures comply with applicable fire and safety requirements and ensure HW areas are operated in compliance with applicable safety standards and IAW DAFMAN 91-203, Air Force Consolidated Occupational Safety Instruction.

4.5 Bioenvironmental Engineering (377 OMRS/SGXB)

• 377 OMRS/SGXB will provide environmental and occupational health consultation services IAW

AFI 48-145, Occupational and Environmental Health Program and AFI 90-821, Hazard

Communication.

• Coordinate and provide technical assistance with identification and disposal of Low Level Mixed

Waste (LLMW).

4.6 Hazardous Material Emergency Planning and Response Team

Designated by the installation commander, ensures adequate preparation and necessary resources for responding to emergency releases IAW AFI 10-2501, Emergency Management Program and the KAFB

SPCC Plan.

4.7 Defense Logistics Agency Disposition Services (DLA-DS)

DLA-DS will assume responsibility for the disposition of HW unless otherwise specified by DLA procedures. Wastes prohibited from disposal by DLA procedures includes but is not limited to explosives, shock sensitive, pyrophoric, radioactive, and etiological wastes.

DLA-DS has the following responsibilities:

• Provides HW disposal contracting and oversight services to installation;

• Signs waste manifests on behalf of the 377 ABW, if delegated, for HW generated by appropriate installation host and tenant units;

• Provides completed HW manifests and EPA land disposal restriction (LDR) certifications based on information provided by the waste generators; and,

• Upon request, provides a copy to the HWP Office (377 MSG/CEIEC) of any HW manifests and

LDR certifications; and can provide the original “closed” HW manifests and a copy of the Poly

Chlorinated Biphenyls (PCB) Certificates of Destruction once received from the treatment, storage and disposal facility (TSDF).

4.8 Judge Advocate, Environment and Real Property (377 ABW/JA)

• When an enforcement action (EA), notice of violation (NOV), RCRA permit, or related documentation/communication is received by the installation, 377 ABW/JA will review the relevant documentation and provide legal advice to CE and the installation commander. 377

ABW/JA will be available, if necessary, to provide legal support at hearings regarding those issues.

4.9 Installation Contracting Offices

• Verify that HW management responsibilities, including reimbursement for disposal where applicable, are written into contracts.

• Provide contracting support and expertise for all contracts that either generate or require the disposal of waste.

• Ensure contractors performing duties on site are held responsible for any waste they generate, do not abandon waste or containers on base, and manage their HW IAW all applicable local, state, and federal regulations.

• Provide timely and effective contracting support to environmental managers to accomplish HW management, as appropriate. This includes using applicable provisions of the Federal Acquisition

Regulation (FAR) and environmental policies and procedures.

4.10 Generating Organizations

A generating organization is one that generates HW, either through a routine process or a one-time or sporadic event (e.g., a spill of hazardous material). Generating organizations at KAFB include all host and tenant units that generate HW. Generating organizations’ responsibilities include but are not limited to:

• Ensuring wastes are properly characterized and appropriate documentation is maintained. The generating organization is the primary repository of documentation related to characterization of the organization’s waste;

• Managing IAPs, UWSs, and WCSs IAW this HWMP, and all applicable policies, regulations, and laws;

• Ensuring positive control is maintained over each IAP, UWS, and WCS, such that at all times, each site is fully under the control of the operator of the process or processes generating the waste;

• Designating Primary and Alternate Unit Environmental Coordinators (UECs) to serve as a point of contact (POC) for the organization’s waste management activities. Per AFI 32-7001, UECs must be appointed by the organization’s commander;

• Designating IAP managers and alternate IAP managers in writing. Only those individuals who are actively involved in generating the HW collected at their site (IAP) may be designated a site manager. IAP managers should not also be designated as UECs;

• For any and all projects with the potential to generate large volumes of hazardous waste, ensuring that planning and coordination with the HW Program occurs well in advance of waste generation.

Failure to coordinate sufficiently in advance limits the abilities of the HW Program to ensure regulatory compliance; potentially delays execution of the project; and significantly increases liability to the organization generating the waste;

• Taking active measures to reduce the volume of HW generated within their organization;

• Those organizations generating 1,000 pounds or more of waste disposed through the hazardous waste program per year, or using HM, must develop, implement, and document written Pollution

Prevention (P2) and waste minimization initiatives and plans (see Section 7.9). Unit UECs will serve as POCs and maintain applicable Waste Minimization Plans;

• Ensuring all personnel whose work involves HW and their immediate supervisors receive and successfully complete Kirtland-specific HW training appropriate to their job responsibilities, to include ensuring these personnel have appropriate proof of training. Training must occur within three months of an employee’s arrival or assignment to HW related duties, and is not limited solely to those individuals who manage a WCS. Please refer to Section 5.5 for a detailed description of individuals whose activities warrant hazardous waste training. Supervisors of these individuals are required to be trained in order to ensure that they have sufficient knowledge to identify instances when hazardous waste generating activities may be out of compliance.

Supervisors and personnel must also successfully complete annual HW refresher training (see

Section 5.0);

• Tenant units whose hazardous waste disposal is not funded with AF O&M will obtain and utilize their own DoDAAC for direct billing.

• Tenant units will reimburse the installation for fines and penalties that the installation commander determines are attributable to their activities.

4.10.1 Unit Environmental Coordinators

UECs will be responsible for performing all the duties delegated to them by their Unit Commanders and/or Supervisors, and ensure WCSs are managed IAW this HWMP and all applicable policies, regulations, and laws. WCSs may also be referred to as an IAP or a UWS depending on the waste being collected.

These duties include but are not limited to:

• Be familiar with the requirements of this Plan and how those requirements apply to all activities undertaken by the unit;

• Ensure a WCS Logbook is maintained for each WCS and updated on a continual basis as needed.

The WCS Logbook contains a variety of records related to daily operation of the WCS. See

Section 6.1 for specifics;

• Provide HW documentation (such as weekly IAP inspection checklists) to HWP upon request;

• Coordinate on all requests for opening or closing waste collection sites;

• Inspect waste collection sites using the quarterly inspection checklist located in Appendix D2 of this plan and report completion of these inspections to kirtlandenvmgt@us.af.mil. Complete a checklist for each individual waste collection site, do not combine inspections of multiple sites on a single checklist. Ensure any deficiencies identified are entered into MICT, and completed checklists are filed in the appropriate WCS Logbook. Note that completion of this checklist is mailto:kirtlandenvmgt@us.af.mil separate from completing the Management Information Control Toolset (MICT) Stage 1 All

Shops Self-Assessment Communicator (SAC).

• Maintain appointment letters designating primary and alternate managers for all waste accumulation sites. Only those individuals who are actively involved in generating the HW collected at their site may be designated a site manager. Appointment letters must be signed by the organizational supervisor or commander, and should be on unit letterhead. See Appendix Q for sample appointment letter text;

• Ensure all personnel whose work involves HW and their immediate supervisors receive and successfully complete Kirtland-specific HW training appropriate to their job responsibilities, to include ensuring these personnel have appropriate proof of training. Training must occur within three months of an employee’s arrival or assignment to HW related duties, and is not limited solely to those individuals who manage a WCS. Please refer to Section 5.5 for a detailed description of individuals whose activities warrant hazardous waste training. Supervisors of these individuals are required to be trained in order to ensure that they have sufficient knowledge to identify instances when hazardous waste generating activities may be out of compliance.

Supervisors and personnel must also successfully complete annual HW refresher training (see

Section 5.0);

• Ensure wastes are properly characterized and appropriate documentation is maintained. Notify the HWP of any changes that may impact waste, including but not limited to addition/deletion of materials in use, changes in equipment in use, etc;

• With site managers, ensure positive control is maintained over each IAP, UWS, and WCS, such that at all times, each site is fully under the control of the operator of the process or processes generating the waste;

• Coordinate with the HWP to ensure wastes pending analysis are characterized within one year of container issue date and relabeled appropriately;

• Maintain active view-only access to the HW module in EESOH-MIS.

• Coordinate HW turn-ins with the HWP, including review of AF2005, container information, and

Waste Segregation Logs prior to container turn in to ensure wastes are properly identified, match the associated process description and container issued, and are compatible with the container’s waste profile.

• Coordinate process and waste changes with the HWP to determine if waste characterization has changed, and with 377 OMRS/SGXB to determine any occupational health risk;

• Notify both the HWP and 377 OMRS/SGXB of all administrative changes in HW activities;

including but not limited to advance notification of planned relocation of processes generating

HW; or the need to temporarily deactivate a WCS. Note that the physical relocation of waste generating processes is not solely an administrative change;

• Ensure that relocation of any process generating waste that is managed through the HWP is fully coordinated with the HWP prior to the relocation occurring. Failure to fully coordinate prior to the relocation can result in work stoppage and/or regulatory noncompliance.

• Take active measures to ensure all activities generating waste are identified and the wastes are managed IAW applicable policies, regulations, and laws, to include proper documentation of waste characterization as required by RCRA;

• Disseminate HW information within organizations and provide generation activities with guidance on characterization, segregation, packaging, and labeling of HW;

• Take active measures to reduce the volume of HW generated within their organization;

• Maintain the organization’s P2 and Waste Minimization Plans, as applicable, and provide related documentation to the HWP upon request;

• Ensure appropriate language is written into all solicitations and contracts from the organization, as applicable, for HW management/handling/training, as outlined in this HWMP;

• Facilitate compliance with the requirements of this HWMP for contractors supporting the organization’s operations;

• With IAP managers, ensure that Site Specific Contingency Plans and emergency response equipment at IAPs are current, properly maintained, and reflective of work being performed in the shop. The Site-Specific Contingency Plan template is located in Appendix M with a completed version to be maintained in the WCS Logbook;

• If spills occur, ensure that appropriate actions are taken IAW the KAFB SPCC Plan and the applicable Site-Specific Contingency Plan. Ensure spill reports are submitted to kirtlandenvmgt@us.af.mil as soon as possible (within 24 hours) after the spill.

• UECs for tenant units without access to eDASH are responsible for requesting from the HW

Program any HWMP documents necessary to ensure compliance with this Plan. EMS documents can be obtained from the EMS Coordinator.

4.10.2 Initial Accumulation Point (IAP) Supervisors/Managers

IAP supervisors/managers must ensure WCSs are managed IAW this HWMP, and all applicable policies, regulations, and laws. WCSs may also be referred to as an IAP or a UWS depending on the waste being collected.

IAP management is not a solely administrative duty. Only those individuals who are actively involved in generating the HW collected at their site may be designated a site manager.

Duties include but are not limited to the following:

• Be familiar with the requirements of this Plan and how those requirements apply to all work performed within the shop;

• Ensure a WCS Logbook is maintained for each WCS and updated on a continual basis as needed.

See Section 6.1 for specifics.

• Ensure alternate IAP managers gain and maintain proficiency in managing their site;

• Ensure weekly IAP inspection checklist is completed by IAP manager or alternate IAP manager and deficiencies are entered into MICT;

• Ensure all personnel whose work involves HW and their immediate supervisors receive and successfully complete Kirtland-specific HW training appropriate to their job responsibilities, to include ensuring these personnel have appropriate proof of training. Training must occur within three months of an employee’s arrival or assignment to HW related duties, and is not limited solely to those individuals who manage a WCS. Please refer to Section 5.5 for a detailed description of individuals whose activities warrant hazardous waste training. Supervisors and personnel must also successfully complete annual HW refresher training (see Section 5.0);

• Maintain active view-only access to the HW module in EESOH-MIS.

• With UECs, ensure positive control is maintained over each IAP, UWS, and WCS, such that at all times, each site is fully under the control of the operator of the process or processes generating the waste;

• Ensure wastes are properly characterized and appropriate documentation is maintained, and notify the UEC and HWP of any changes that may impact waste characterization;

• If a WCS will manage waste that is incompatible with both steel and poly waste containers, ensure the incompatibility is documented with the UEC and HWP, and has been fully addressed prior to generating the waste;

• With UEC, coordinate with the HWP to ensure wastes pending analysis are characterized within one year of container issue date and relabeled appropriately;

• Review Waste Segregation Logs prior to container turn in to ensure wastes are properly identified, match the associated process description, and are compatible with the container’s waste profile;

• With the UEC, coordinate process and waste changes with the HWP to determine if waste characterization has changed, and with 377 OMRS/SGXB to determine any occupational health risk;

• Notify the UEC, the HWP, and 377 OMRS/SGXB of all administrative changes in HW activities, including but not limited to advance notification of planned relocation of processes generating

HW; or the need to temporarily deactivate a WCS. Note that the physical relocation of waste generating processes is not solely an administrative change;

• Take active measures to reduce the volume of HW generated within their organization;

• With the UEC, ensure that Site Specific Contingency Plans and emergency response equipment at

IAPs are current, properly maintained, and reflective of work being performed in the shop. The

Site-Specific Contingency Plan template is located in Appendix M with a completed version to be maintained in the WCS Logbook;

• If spills occur, ensure that appropriate actions are taken IAW the KAFB SPCC Plan and the applicable Site-Specific Contingency Plan. Ensure spill reports are submitted to kirtlandenvmgt@us.af.mil as soon as possible (within 24 hours) after the spill.

4.11 Hazardous Waste Accumulation Site (HWAS) Contract Support

• Perform services in support of HW management and in compliance with the Hazardous Materials

Transportation Act (HMTA), Comprehensive Environmental Response, Compensation, and

Liability Act (CERCLA), Resource Conservation and Recovery Act (RCRA); other applicable federal (including 40 Code of Federal Regulations [CFR] Part 264/265, Subparts A through E), state, and local laws and regulations; related DoD and AF directives (including AFMAN 32-

7002); and this Plan.

• Adhere to all AF policies and goals on HW reduction in addition to all federal, state, and local

HW regulations.

• Provide services as outlined in the AFCEC “Fence-to-Fence Environmental Services at Kirtland

Air Force Base” Performance Work Statement (PWS), (Call Order# ID07200023), to include but not limited to:

o Management/accomplishment of waste pickup;

o Transporting wastes to the <90-day facility;

o Appropriate weighing, labeling/marking and segregation of all wastes within the <90-day facility;

o Prepare HW containers for shipment and coordinate with DLA-DS and transport/disposal contractors for turn-in/pick-up/loading of HW (as required by DLA-DS and the

Transporter);

o Provide HM and HW spill response services within one (1) hour of notification by installation personnel to include after-hours and emergency spill response, as applicable;

o Support/assist the installation HW POC with the Staff Assistance Visit (SAV) process to ensure that every IAP on the installation is visited by the SAV process at least once per year;

o Assisting in the administrative requirements of the HW module in the web-based

Enterprise Environmental Safety and Occupational Health-Management Information

System (EESOH-MIS); and, o Assisting in potential industrial recycling processes.

5.0 TRAINING

5.1. Hazardous waste 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 5.5.

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

5.3. Hazardous waste program managers and alternates appointed in writing by the Wing Commander to sign manifests, require specific training to include HW Management Compliance Training and Department of Transportation training to sign HW manifests. Installation HW Program Managers should complete the following in-residence courses (or equivalent): Air Force Institute of Technology (AFIT) 521, Hazardous

Waste Management; and DLA - DCPSO00510, Transportation of Hazardous Material/Hazardous Waste

(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.

5.4. Training (Local In-House/On-Line Training Sources): (Group A) Organizational (non-central)

Hazardous Waste Storage Area Managers, Satellite Accumulation Area (Initial Accumulation Point)

Managers, and their immediate supervisor; and (Group B) all shop personnel, and their immediate supervisors, who generate HW.

Installation Supplement – Training

5.5 Personnel Requiring Training

Personnel whose duties include activities that generate hazardous waste, or whose duties include management of hazardous waste, are required to have “function-specific” training to fulfill their respective position duties. Personnel who require hazardous waste training include but are not limited to individuals in the following roles: hazardous waste generators (including temporary, transient, or term employees such as students or mod teams); UECs; primary/alternate WCS/IAP managers; <90-day staff;

maintenance staff; and spill response personnel. Supervisors of these individuals also must complete HW training.

Tasks performed by the above-listed personnel with HW management duties include, but are not limited to, the following:

• Creating waste, including but not limited to using hazardous materials with or without use of consumable items such as rags;

• Deciding which wastes are hazardous, to include returning used consumables to a tool crib for check-in;

• Adding HW to waste collection site containers;

• Performing HM/HW spill cleanup;

• Inspecting and/or operating waste collection sites;

• Ensuring timely initiation of all HW removal/turn-in actions/documentation to prevent overflows and crisis situations;

• Managing the shop’s hazardous materials program; and,

• Conducting other HW-related activities, as necessary, to support federal, state and local (KAFB)

HW program management requirements.

5.5.1 Kirtland-specific HW Training

Individuals who generate HW must have sufficient training to be able to identify a RCRA-regulated HW and manage it IAW this Plan. To facilitate this level of knowledge, the HWP provides a computer based training (CBT) module, currently available on TEACH. This CBT is intended as baseline training, and must be viewed in its entirety in order to successfully provide baseline training. Individuals without computer access should coordinate with their UEC for alternate accommodations to ensure baseline training is completed in a timely fashion.

Shops and/or units are responsible for providing any additional training specific to the work center, to include familiarizing shop personnel with emergency procedures, equipment, and applicable emergency systems. Additional training provided by the shop or unit shall not be substituted for the full CBT provided by the HWP, regardless of the content of the additional training.

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 Waste Collection Site (WCS) Logbook

Every WCS shall have a Logbook, maintained and updated by the organization generating the waste.

Refer to Appendix E for a standardized Table of Contents and document retention requirements for the

WCS Logbook. Blank versions of forms appearing in Appendices D-I and Appendices L, M, and O are located on eDASH. Contact the HW Program if further guidance is necessary.

6.2 Training Documentation

Supervisors of employees who work with HW are responsible for identifying the employee’s training requirements, coordinating the training, and documenting the training. Note that retention requirements appearing in Section 6.0 for employee training records apply to HWAS staff and not WCS staff.

Various DoD and USAF approved tracking tools may be used to record HW training; however, written records of HW training completion must be maintained in the Unit WCS Logbooks. Per AFMAN 32-

7002, these records must include the following:

• 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.

6.3 Inspection Documentation

Documentation of inspections and other related WCS records shall be maintained in the WCS Logbook.

See Appendix E for recommended document retention requirements.

Program-level compliance assessments will be documented by 377 MSG/CEIE in the eDASH Finding

Tracker Tool.

6.4 Required Documentation for HWAS Support Contractors

The AFCEC “Fence-to-Fence Environmental Services at Kirtland Air Force Base” Performance Work

Statement (PWS) outlines the required…