48th FIGHTER WING (USAFE)
Hazardous Waste Management Plan June 2020
ABOUT THIS PLAN
This installation-specific Environmental Management Plan (EMP) is based on the U.S. Air Force’s (AF) standardized Hazardous Waste Management Plan (HWMP) template for overseas installations. This plan is not an inventory of all hazardous waste (HW) requirements and practices. External resources, including Air Force Instructions (AFIs); AF Playbooks; Final Governing Standards (FGS); and permit requirements, are referenced.
Each section of this plan begins with standard language that addresses AF and Department of Defense (DoD) policy and federal requirements. The standard language is restricted from editing to ensure consistent application across the AF enterprise. Standard language is maintained by the Air Force Civil Engineer Center (AFCEC) designated Subject Matter Expert (SME) for this plan.
Immediately following the standard text are installation-specific sections that address state, local, and installation-specific requirements and processes. Installation sections are maintained and updated by the installation hazardous waste management program manager and/or the Air Force Installation and Mission Support Center – Detachment 4, Environmental Section (AFIMSC Det 4/CEIE) support appointed to support this installation.
This document is optimized to be accessed and viewed electronically on the installation and Air Force eDASH website, the primary communication tool for AF EMPs.
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TABLE OF CONTENTS DOCUMENT CONTROL ...... 4 1.0 OVERVIEW AND SCOPE ...... 6 2.0 INSTALLATION PROFILE ...... 7 3.0 ENVIRONMENTAL MANAGEMENT SYSTEM ...... 8 4.0 GENERAL ROLES AND RESPONSIBILITIES ...... 8 5.0 TRAINING ...... 12 6.0 RECORDKEEPING AND REPORTING ...... 13 7.0 PROCEDURES ...... 16 7.1 Waste Inventory ...... 16 7.2 Waste Identification ...... 16 7.3 Container Management ...... 17 7.4. Labeling and Marking ...... 18 7.5 Hazardous Waste Management ...... 19 7.6 Transportation ...... 21 7.7 Turn In/Disposal ...... 21 7.8 Inspection ...... 23 7.9 Waste Minimization ...... 23 7.10 Preparedness and Prevention ...... 24 7.11 Waste Specific Procedures ...... 25 8.0 REFERENCES ...... 28 9.0 ACRONYMS ...... 28 10.0 DEFINITIONS ...... 29 11.0 INSTALLATION-SPECIFIC CONTENT ...... 29 Appendix A – Waste Analysis Plan ...... 30 Appendix B – Information and Emergency Contacts ...... 42 Appendix C – RAF Lakenheath HWSA Closure Plan ...... 43 Appendix D – RAF Lakenheath and RAF Feltwell HWAP Facility Listing ...... 45 Appendix E – Sample Forms and Templates...... 46
Page 3 of 55 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 by the HW and Environmental Overseas SME. This version of the template is current as of 10/03/2018 and supersedes the 2015 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 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’s Office of Primary Responsibility (OPR).
Record of Updates
Change No. Nature of Change Date of Change Approved By: 0 Standardization of 3/17/2017 R Webb HWMP 1 Standardization of 3/7/2019 R Webb Appendix A 2 Change to record 7/12/2019 R Webb keeping 3 Updated to latest 11/22/2019 R Webb standardized template and comprehensively updated all installation- specific sections and appendices. 4 AFMAN 32-7002 3/31/2020 R Webb supersedes AFI 32-7086 AFI 32-7042 5 Administrative 5/12/2020 R Webb changes, i.e. grammar and syntax. 6 Administrative changes to E1 10/21/2020 R Webb HWAP Inspection Sheet Click here to enter text. Click here to enter text. Click here to enter a Click here to enter text. date.
Page 4 of 55 Record of Annual Review – In accordance with (IAW) AFMAN 32-7002, Waste Management, this plan is reviewed annually by the Environmental Management System (EMS) Cross Functional Team (CFT). Formatting and administrative changes should be noted in the above 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.
Record of EMS CFT Annual Review
Result in Plan Review Date Review Participants Notes/Remarks Update? (Yes or No) 4/5/2018 ECFT No Changes YES 4/4/2019 ECFT Standardization of YES Appendix A 6/8/2020 ECFT Approved at ECFT YES
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Page 5 of 55 1.0 OVERVIEW AND SCOPE This HWMP contains procedures for management of HW. In addition to the FGS requirements, or if no FGS exists, the Overseas Environmental Baseline Guidance Document, AFMAN 32- 7002, acts as a main driver for the HWMP. The HW Playbook serves as supplemental guidance to this plan. Installation Supplement – Overview and Scope Purpose This plan serves as primary guidance for managing HW activities at Royal Air Force (RAF) Lakenheath and RAF Feltwell. It provides a management overview and specific requirements for the successful execution of the HW program. If there is a conflict between this plan and regulatory guidance, the regulatory requirements will take precedence. This plan is intended to assist operators, technicians and managers in meeting 48 FW HW program requirements. The cooperative efforts of many organizations and individuals are required for effective implementation of the 48 FW HW program.
Overview
This HWMP establishes the overall strategy, delineates responsibilities, and sets forth specific objectives for effective management of HW at RAF Lakenheath and RAF Feltwell. Effective HW management requires active, continuing participation at all levels of management. This plan supports AF directives and is intended to ensure compliance with the applicable Final Governing Standards for the United Kingdom (FGS-UK), DoD, and AF requirements.
Environmental Office, 48 Civil Engineer Squadron (CES)/CEIE, Annual Review Procedures
The installation environmental office, 48 CES/CEIE, annually conducts an internal review of the HWMP. The following sections and tables must be reviewed, usually prior to the annual review by the EMS CFT, to ensure accuracy and consistency. • Section 2 – Installation Profile • Section 4 – General Roles and Responsibilities • Section 8 – References • Appendix D – RAF Lakenheath and RAF Feltwell HWAP Facility Listing
Guidance
AFMAN Waste Management provides AF HW management guidance, which requires each installation to develop a plan outlining an overall program strategy. This plan satisfies those requirements.
• Hazardous Communication (HAZCOM). This plan does not discuss requirements for the hazardous communication program. LAKI 90-802, Workplace Hazard Communication Program, defines the requirements for the HAZCOM program. • Hazardous Materials (HAZMAT) Management. HAZMAT requirements are covered in AFMAN 32-7002, HAZMAT Management is not covered in this plan. • Hazardous Materials Spill Prevention and Response Plan. This HWMP does not describe the actions and reporting requirements for spills or releases of HAZMAT. That information is found in the 48 FW 32-4013 Hazardous Materials Spill Prevention and Response Plan.
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Legal Considerations
The objectives, policies and procedures included within this plan are in effect when approved by the 48 FW ESOHC chairperson, responsible for implementing AF environmental policy at RAF Lakenheath and RAF Feltwell. This plan may direct management requirements that are more stringent than regulations. If a conflict arises between this plan and regulatory requirements, such as the FGS-UK, regulatory requirements take precedence.
Final Governing Standards. The FGS-UK, 2017, provides specific standards for environmental protection at DoD installations in the United Kingdom (UK). The standard’s requirements are included in the Overseas Environmental Baseline Guidance Document (OEBGD), DoD Instruction (DODI) 4715.5, Management of Environmental Compliance at Overseas Installations and Executive Order (EO) 12088, Federal Compliance with Pollution Control Standards.
• The FGS-UK C6.3.3.3.1 requires that a waste analysis plan (WAP) is developed to determine how and when wastes are analyzed. This requirement is satisfied in Appendix A of this plan.
2.0 INSTALLATION PROFILE Installation Profile
Scope of Plan This plan is designed to define processes related to the HW management program at RAF Lakenheath and RAF Feltwell.
Office of Primary Responsibility 48 CES/CEIE at DSN 226-3990 has overall responsibility for (OPR) implementing the HW management program and is the lead organization for monitoring compliance with regulations HW Program Manager Rebecca Webb: [email protected] DSN: 314-226-3989 Alternate HW Program Kylene Lang: [email protected] Manager DSN: 314-226-5985 Emergency contacts Fire Department - 911 Emergency Medical Care – 911 Refer to Appendix B for additional contacts Waste registration numbers RAF Lakenheath - Feltwell DLA-DS. DLA-DS is the code used for all UK installations as there is no EPA Registration Number for overseas installations FGS regulatory references FGS-UK, Chapter 6 Local regulatory agencies Defence Infrastructure Organization/Environment Agency Local regulatory references Not Applicable Approved HW disposal Defense Logistics Agency Disposition Services (DLA-DS) contractors HW storage areas Building 1218, RAF Lakenheath HW accumulation time limits No time limits during accumulation at HWAP; 1 year at HWSA HW generator reporting Not Applicable frequency
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3.0 ENVIRONMENTAL MANAGEMENT SYSTEM
The AF environmental program adheres to the EMS framework and its Plan, Do, Check, Act cycle for ensuring mission success. EO 13693, Planning for Federal Sustainability in the Next Decade, U.S. DoDI 4715.17, Environmental Management Systems, AFI 32-7001, Environmental Management, and International Organizations 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 managing associated risks, and instilling a culture of continuous improvement. The HWMP serves as an administrative operational control that defines compliance-related activities and processes.
4.0 GENERAL ROLES AND RESPONSIBILITIES
The major roles/organizations involved in supporting the HW program include:
• Wing/Installation Commander • ESOHC • HW Program Manager/Alternate • Shop/HW Generator Personnel • Hazardous Waste Accumulation Point (HWAP) and Hazardous Waste Storage Area (HWSA) Supervisors/Managers • Unit Commanders • Unit Environmental Coordinators (UECs), see AFI 32-7001 for role description • Contracting Officer • Defense Logistics Agency Disposition Services (DLA-DS) • Tenant Organizations • AFCEC
Detailed information about typical responsibilities for these and other roles is available in AFMAN 32- 7002, applicable installation supplements, and the HW Playbook. Additional HW management-related roles and responsibilities are described throughout this plan and in referenced documents.
Installation Supplement – General Roles and Responsibilities
Specific responsibilities for organizations and personnel tasked with HW program management and implementation are described in the following paragraphs.
Installation Commander – 48 FW/CC
• Be responsible for compliance with the FGS-UK and regulations applicable to HW. • Sign, or delegate in writing, the authority to sign HW consignment notes. Signature delegation shall remain with active duty and AF civilian employees only. • Ensure that HAZMAT is made available for reuse to the maximum extent possible before disposal. • Signs HW permit applications or other regulatory binding agreements as required.
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Environmental, Safety and Occupational Health Council (ESOHC)
• Chaired by 48 MSG/DC. • Direct matters involving HW management. • Review HW management procedures as needed and resolve any conflicts or areas of noncompliance. • Reviews and approves HWMP when substantive changes are proposed.
Environmental Management System Cross Functional Team (EMS CFT)
• Reviews HWMP, at least annually, with administrative changes annotated in the plan by the 48 CES/CEIE HW Program Manager, without need for ESOHC approval. • Documents EMS CFT annual review in HWMP Record of Annual Review. Civil Engineer Squadron – 48 CES/CC
• Assign, equip and train sufficient personnel to support the implementation of this plan by the OPR, 48 CES/CEIE. • Ensure contractors working on behalf of RAF Lakenheath and RAF Feltwell Civil Engineer (CE) projects comply with all necessary requirements for the collection and disposal of HW.
Installation Management Flight, Environmental Management Element – 48 CES/CEIE
• Establish local procedures, prepare and maintain management plans and provide technical expertise with regard to waste management requirements and preparation of a Hazardous Waste Profile Sheet (HWPS) for transport and disposal of HW. • Review HWPS using information provided by the waste generator, Safety Data Sheet (SDS) and analytical results, if applicable. • Maintain a copy of each HWPS IAW retention times prescribed by the Air Force Records Disposition Schedule. • Develop and submit five-year budget requests for facilities, personnel, training, and other waste management needs. • Oversee proper programming and record keeping procedures. • Prepare, review and update the WAP IAW Appendix A. • Provide sampling and analysis of HW as necessary for proper characterization, management and disposal. • Complete HW reporting requirements as necessary, including submittals for data calls. • Coordinates and supervises the HW training for all RAF Lakenheath and RAF Feltwell personnel IAW Section 5.0. • Provide technical assistance for generators for MICT Stage 1 SAC assessments as needed. • Manage the HWSA. • Prepare waste shipping documents in coordination with DLA-DS. • Participate in approval of HWAP and HWSA locations. • Liaises with AFIMSC DET 4/CEIE for requests of waste management services (WMS) through DLA-DS. • Monitors DLA-DS contractor performance and reports discrepancies/concerns to contracting officer representative (COR) and AFIMSC DET 4/CEIE. • Performs CE annual oversight inspections of HWAPs and HWSA IAW Section 7.8. • Provides technical expertise to generating activities regarding waste management.
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• Ensures funding requirements are properly identified and reported to AFIMSC DET 4/CEIE. • Maintains HWSA records IAW Section 6.0. • Re-validates HWAP waste streams annually by evaluating the shops’ HWPS.
Fire Protection Flight – 48 CES/CEF
• Provide guidance, technical expertise and assistance to implement this plan. • Participate in approval of HWAP and HWSA locations.
Installation Dangerous Goods Advisor – 48 MSG/IDGA
• Provide advice for the safe transport of HW from or within RAF Lakenheath and RAF Feltwell. • Coordinate Dangerous Goods Certifier training for those 48 CES/CEIE personnel designated to sign HW consignment notes. • Advise the generator on completion of the proper shipping information, containers and transportation requirements in the HWPS.
Contracting Squadron – 48 CONS
• Provide contracting support and expertise for all contracts that either generate or require the disposal and movement of waste. • Provide timely and effective contracting support to 48 CES/CEIE to accomplish HW management, as appropriate, including using applicable provisions of the Federal Acquisition Regulation (FAR) and environmental policies and procedures.
Bioenvironmental Engineering (BE) Flight – 48 AMDS/SGPB
• Advise the generator on completion of the health portions of the HWPS, on request. • As requested, participate in approval of HWAP and HWSA locations. • Provide environmental and occupational health consultation services IAW AFI 48-145, Occupational and Environmental Health Program.
Safety – 48 FW/SE
• Review the HWSA and HWAPs for safety issues while performing facility safety inspections. • Ensure plans and procedures comply with applicable safety requirements. • As requested, participate in approval of HWAP and HWSA locations.
Judge Advocate – 48 FW/JA
• Identify applicable HW management laws, regulations, EOs and policies for the ESOHC. • Provide advice to ensure compliance and provide legal support at hearings.
Plans and Programs – 48 FW/XP
• Consult with tenant unit and 48 CES/CEIE to determine tenant unit HW support requirements during development of Support Agreements (SA). • Define requirements and responsibilities in SA.
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Work-Area Supervisors of HW Generating Activities
• Manage HW and HWAP IAW the FGS-UK and this plan in coordination with 48 CES/CEIE. • Ensure a primary and alternate HWAP monitor is assigned by the shop supervisor. Appointments must be documented electronically by e-mail to the 48 CES/CEIE HW Program Manager. • Attend HW management training, both initial and annual refresher IAW Section 5.0. • Ensure all personnel that are assigned duties involving actual or potential exposure to HW are trained IAW Section 5.0. • Coordinate with 48 CES/CEIE to characterize (i.e. to determine whether or not they are hazardous) all wastes and prepare HWPS. • Ensure that all new and existing waste streams and/or process changes have been coordinated with 48 CES/CEIE, 48 CES/CEF, 48 FW/SE and 48 AMDS/SGPB. • Notify HWSA personnel when HW containers are full to schedule pickup. • Ensure requirements for proper HW management, such as labeling and disposal, are implemented • Maintain documentation and recordkeeping IAW this HWMP. • Notify 48 CES/CEIE of unknown wastes. • Ensure shops have an adequate supply of materials and equipment to accommodate routine collection of HW and any potential emergency situations (i.e. spill kits). • Prepare and update a Site Specific Spill Plan and ensure all personnel are trained on spill prevention and response procedures. • Support and implement HW minimization or pollution prevention initiatives directed by the 48 FW ESOHC. • Minimize HW generation to the maximum extent possible by following the HAZMAT management procedures of AFMAN 32-7002.
Hazardous Waste Accumulation Point (HWAP) Monitors and Alternates
The HWAP Monitors and Alternates are appointed by their supervisor. The supervisor will email the 48 CES/CEIE HW Program Manager to update the training/appointment tracker. All generators of HW must be capable of recognizing, tracking and maintaining all documentation necessary for proper HW management. The HWAP Monitors and Alternates main duties include:
• Manage HWAPs IAW HWMP and all applicable policies, regulations, and laws. • Successfully complete annual RAF Lakenheath Hazardous Waste Monitor Training given by 48 CES/CEIE HW Program Managers prior to working unsupervised with HW IAW Section 5.0. • Conduct HW Awareness Training to individuals that handle or have the potential to be exposed to HW IAW Section 5.0. • Coordinate with 48 CES/CEIE HW Program Manager, 48 CES/CEF, and 48 FW/SE on initial location or relocation of HWAPs IAW Section 7.5. • Ensure proper HW procedures are followed IAW Section 7.0. • Conduct weekly inspections of their HWAPs IAW Section 7.8. • Notify 48 CES/CEIE HW Program Manager when a change in type or quantity of HW generated will occur to ensure contract requirements for disposal can be processed in a timely manner.
Unit Environmental Coordinator (UEC)
• Attend HW management training as required by 48 CES/CEIE. • Assist HW monitors, supervisors, and unit staff with staying in compliance with this plan.
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Tenant Organizations
• Comply with all requirements of the FGS-UK and this HWMP, unless exempted by DoD/AF Instructions. • HW support for tenant organizations will be defined in the tenant organization Support Agreements.
Defense Logistics Agency Disposition Services (DLA-DS)
• Provide HW disposal contracting and oversight services. Provides copies of HW manifests and delivery orders (including modifications) to 48 CES/CEIE HW Program Manager. • Verifies accuracy of HW weights prior to acceptance and completion of disposal actions. • Reviews and verifies HWPS and manifests prior to acceptance and completion of disposal actions. • Coordinates HW removal between contractor and 48 CES/CEIE HW Program Manager.
Defence Infrastructure Organization (DIO) (formerly Defence Estates)
Defence Infrastructure Organization consigns and tracks wastes generated through their contracts on behalf of the U.S. Visiting Forces.
• Defence Infrastructure Organization assigns their own consignment note code numbers for shipments and tracks those shipments on a separate database from the 48 FW HW shipments. • Defence Infrastructure Organization retains copies of the consignment notes for three (3) years, per UK requirements. • Each year, DIO renews the site HW registration for RAF Lakenheath and RAF Feltwell by 14 July and provides this number to 48 CES/CEIE.
5.0 TRAINING
Hazardous Waste awareness training is provided to satisfy AFMAN 32-7002 and country-specific FGS requirements and needs. All personnel whose work involves HW, and their immediate supervisors, must successfully complete HW training appropriate to their job responsibilities. Until the employee has received the appropriate HW training, the employee may only handle HW under the supervision of a trained individual. Hazardous Waste training is provided by authorized personnel. Training records are maintained IAW the Recordkeeping and Reporting section of this plan. Installations will enter procedures regarding site-specific training requirements below based upon FGS and Host Nation (HN) regulations, consistent with the eDASH training matrix.
Installation Supplement – Training
Installation Hazardous Waste Program Manager Training
The 48 CES/CEIE HW Program Manager will complete the following training:
• New HW Program Managers will complete initial HW training by completing the Air Force Institute of Technology (AFIT) Hazardous Waste Management Course WENV 521. • Annual refresher training requirements can be satisfied by conducting the RAF Lakenheath Hazardous Waste Monitor Training or attending USAFE HW refresher training events hosted by
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AFIMSC Det 4/CEIE. • European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR) Certifier training in order to certify HW shipments leaving the installation (initial with annual refresher).
Hazardous Waste Accumulation Point (HWAP) Monitors and Shop Personnel Training
In accordance with FGS-UK C6.3.9.1, personnel and their supervisors assigned to duties involving actual or potential exposure to HW must successfully complete an appropriate training program prior to assuming those duties. These tasks include generation, movement, handling or characterization.
• Hazardous Waste Accumulation Point Monitors (primary and alternates) and shop supervisors must attend the RAF Lakenheath Hazardous Waste Monitor Training. This training is administered in person by the 48 CES/CEIE HW Program Manager. • Shop-level worker training is developed by the HWAP Monitors and supervisors for their particular shop. A training template is provided by 48 CES/CEIE outlining the required information and is available on the 48 CES/CEIE eDASH SharePoint website. This document should be kept electronically and updated for correctness on a yearly basis or if a new waste stream is introduced into the shop. As long as the template is followed, 48 CES/CEIE does not need to approve the training slides. Any deviation from the template requires approval. • In accordance with FGS-UK C6.3.9.2, refresher training is accomplished annually for Shop Level Workers and HWAP Monitors. • After the HWAP Monitor delivers the training, a record of all shop personnel trained will be kept. A training record template is available on the 48 CES/CEIE eDASH SharePoint page. Shops will send the tracker to the 48 CES/CEIE HW Program Manager on the first week of July each year, where it will be kept for three years. • Only the 48 CES/CEIE HW Program Manager can approve alternative training to satisfy FGS-UK requirements. • Training records must be maintained for as long as personnel are present at the site and at least three (3) years after termination of HW duties at the site.
Hazardous Waste Storage Area (HWSA) Personnel Training
Individuals’ assigned duties at the HWSA will complete the following training:
• RAF Lakenheath Hazardous Waste Monitor Training (annually) • Dangerous Goods Certifier Training (initial with annual refresher)
Shipment Personnel Training
Individuals who sign consignment notes on behalf of 48 FW should be ADR certified and designated by the Wing Commander.
6.0 RECORDKEEPING AND REPORTING
Recordkeeping
The installation complies with the following HW recordkeeping requirements, as applicable, based on generator status. Records may be kept in either paper or electronic form.
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Summary of HW Recordkeeping Requirements
Record Retention Time Citation HW determination 3 years from the closure of the HWSA and FGS-UK documentation HWAP Section C6.3.5.6 HW manifest (turn-in 3 years FGS-UK document) Section C6.3.5.1 HWSA logs Until closure of installation FGS-UK Section C6.3.5.3 Hazardous waste inspection 3 years FGS-UK logs Section C6.3.5.4 Employee HW training 3 years from date of termination of duties FGS-UK records Section C6.3.9.4
Reporting
The 48 CES/CEIE HW Program Manager, and other designated personnel, generate needed reports from EESOH-MIS (Enterprise Environmental Safety Occupational Health-Management Information system).
Enforcement actions, spills and inspections are reported via the Enforcement Actions, Spills, and Inspections (EASI) database.
Installation Supplement – Recordkeeping and Reporting
Hazardous Waste Accumulation Point (HWAP) Recordkeeping Requirements
Hazardous Waste Accumulation Points are required to maintain the following records, either hard copy or electronic.
Site-Specific Spill Plan. Each HWAP must have a site specific spill plan that addresses spill procedures at that location and is formatted IAW 48 CES/CEIE requirements. The 48 CES/CEIE Spill Manager will review the plan for completeness. The plan must contain an accurate site map that includes at a minimum the locations of HWAP and HAZMAT storage lockers, drain locations, spill kits, fire extinguishers, eyewash stations and Personal Protective Equipment (PPE).
Spill Reporting Procedure. Refer to 48 FW 32-4013, Section 4.2.8. Spill Cleanup, Storage, and Disposal, Section 4.2.9. Post Spill Incident Response, and 4.3. Industrial Discharge (Slug) Response Procedures located on eDASH at the following link: https://cs2.eis.af.mil/sites/10626/Lakenheath/WPP/ProgramPage/Hazardous%20Waste.aspx.
Hazardous Waste Storage Area (HWSA) Documentation Requirements
• Hazardous Waste Storage Area Log. Recordkeeping of all HW containers picked up, transported to the HWSA, and shipped offsite for disposal is maintained in EESOH-MIS and available at any time by using the system’s reporting features. This information will be maintained until closure of the installation. o A written log (electronic) will be maintained to record all HW handled and should consist of the following: . Name/address of generator; . Description and hazard class of the HW;
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. Number and types of containers; . Quantity of HW; . Date stored; . Storage location; . Disposition data to include: dates received, sealed, transported, and transporter used; o The HW Log will be available to emergency personnel in the event of a fire or spill. o Log will be maintained until closure or transfer of the installation. • Weekly Inspections. The HWSA must be inspected at least every seven days to include containers and equipment on site – see Appendix E – Sample Forms and Templates. Inspection logs are maintained by 48 CES/CEIE on site, and maintained for three (3) years. • Hazardous Waste Storage Area Contingency Plan. The contingency plan details emergency procedures and maintained by 48 CES/CEIE on site. • Hazardous Waste Storage Area Closure Plan. A closure plan will be maintained for the HWSA by 48 CES/CEIE. It is located at Appendix C. • Hazardous Waste Tracking System (electronic) o EESOH-MIS is the standardized Air Force HW tracking & reporting system. EESOH- MIS functions will be maintained to provide for: . Real time tracking of every container issued by the HWSA . Site lists, waste stream lists, and waste codes . HW and waste oil processed through the HWSA, by organization, quantity, and type
48 CES/CEIE will maintain program plans, documents, and templates referenced in this section on the RAF Lakenheath environmental eDASH website at the link below: https://cs2.eis.af.mil/sites/10626/Lakenheath/WPP/ProgramPage/Hazardous%20Waste.aspx
Training Documentation
Proper documentation is essential to an effective training program. Section 5.0 Training defines training requirements for the HW program. Training records must be kept to provide evidence that the training was successfully completed; these records must be available for internal, as well as external, inspections. Training records for HWAP Monitors and shop personnel and training records for HWSA personnel are kept at the 48 CES/CEIE office. Additionally, the 48 CES/CEIE HW Program Manager maintains a spreadsheet tracking the appointment of HWAP Monitors and their most recent training completion dates. Training records for the 48 CES/CEIE HW Program Manager must be kept in the 48 CES/CEIE Environmental Office files. Training records must be kept for current employees as long as they work at the installation and for an additional three (3) years after the date they leave the base (or stop working at a position related to HW management).
Reporting Spill Reporting 48 FW procedures, as outlined in the Spill Prevention and Response Plan, require responsible organizations to report releases of any amount of HW releases to the 48 CES/CEIE Environmental Office at 226-3990 and to the Fire Department.
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7.0 PROCEDURES
This section contains procedures for managing HW from identification, accumulation, offsite transportation and disposal. The 48 CES/CEIE HW Program Manager ensures that appropriate procedures are properly communicated and followed by all necessary personnel.
7.1 Waste Inventory
A current waste inventory can be generated within EESOH-MIS using the Ad-Hoc Reporting Tool or by completing the following steps:
• Log into EESOH-MIS; Select the “Reporting” option; Select “Hazardous Waste” to generate the Waste Site Waste Stream Summary Report.
Installation Supplement – Waste Inventory
The HWSA Manager or 48 CES/CEIE HW Program Manager should be contacted in the event that a current waste inventory for RAF Lakenheath or RAF Feltwell is needed and they will then generate a current report from EESOH-MIS using the steps outlined above.
Hazardous Waste (HW) Stream
A HW stream is defined as HW that has the same properties that allow it to be shipped off-base under the same information. Each waste stream is assigned a HWPS number.
Hazardous Waste Accumulation Point Monitors or shop supervisors must immediately contact the 48 CES/CEIE HW Program Manager when potentially generating a new waste stream. See Appendix E – Sample Forms and Templates for the Hazardous Waste Stream Review Request form.
7.2 Waste Identification
The 48 CES/CEIE 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 HAZMAT. If uncertainties about a waste stream exist, the 48 CES/CEIE HW Program Manager pursues waste stream sampling and analysis IAW the WAP found in Appendix A.
The WAP details the wastes that have been evaluated and analyzed, a description of the testing and analytical methods used, the HW sampling methods used, the location of samples taken for analysis and frequency, sample documentation, sample quality assurance and quality control procedures, and sample request procedures.
Generator knowledge and the results of the WAP are used to minimize waste re-characterizations to those instances where a process change has occurred or the waste stream is highly variable.
Installation Supplement – Waste Identification
Refer to the WAP found in Appendix A for RAF Lakenheath-specific waste identification procedures.
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7.3 Container Management
Container management procedures are as follows:
• Containers storing HW must be in good condition and meet permit, transportation and other applicable requirements. “Good condition” means there should be no severe rusting, no sharp- edged creases or dents, no bulging heads and no severe structural defects. • Ensure that the waste material will not react with the container itself. • Use plastic or plastic-lined steel drums to safely store corrosive wastes. • Immediately transfer the contents of a leaking container to another container or over pack into a salvage drum. • Containers with free liquid or drum contents on top must be cleaned or over packed in the case of a leak. • Containers must remain closed at all times except when adding or removing waste. Adequate headspace must be maintained at all times when filling a container to account for content expansion. • Containers holding HW must not be opened, handled, or stored in a manner which may rupture the container or cause it to leak. • Containers of flammable liquids must be grounded when transferring flammable liquids from one container to the other.
Installation Supplement – Container Management
Hazardous Waste Accumulation Point Monitors may obtain the appropriate, empty containers from the HWSA. It is the ultimate responsibility of the HWAP and HWSA Managers to ensure the HW containers are managed according to the requirements described in Section 7.3, Container Management.
The following precautions should be taken at HWAPs and the HWSA to prevent container ruptures and leaks:
• Containers must not be overfilled. A minimum 6-inch gap will be maintained to allow for expansion and for drum movement. • Closed head containers must be filled using a funnel. • Drums must not be stacked more than two high. Drums containing flammable liquids must not be stacked. • Containers should be stored in an area, which is away from or protected from damage due to the movement of vehicles such as trucks, forklifts, etc. • Drums and other containers must be handled and transported with equipment designed for the task. Drum grappler attachments may be purchased for tow motors to securely grab and move containers. Secure containers to pallets before moving pallets. Use drum carts designed for the types of containers used by your organization to reduce the likelihood of dropping a container during handling. Never balance drums on the forks of a forklift or tow motor. • Containers must remain closed at all times, except when waste is added or removed. Closed means that for open-top drums, the lid is securely closed using the clip or nut and bolt on the drum ring. For closed-top drums, the bung cap is in place and tightened. For drums accumulating liquids that are filled through a funnel, the funnel must be closed unless adding fluids.
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Secondary Containment
Container storage areas must have a secondary containment system meeting the following requirements:
• If HW liquids are accumulated, they must be kept on secondary containment spill pallets both indoors and outdoors. • Containment must be monitored for spills and the spillage removed when it is identified. • Containment must be adequately sized to hold 25% of the volume of stored containers or 110% of the volume of the largest container, whichever is greater. • Separate containment is required for incompatible hazards.
Hazardous Waste Storage Area (HWSA)
Container Management
• Adequate aisle space must be maintained to allow free movement of personnel, firefighting equipment and spill prevention materials. • Containers cannot block entry or exit points. • Containers must be segregated by appropriate hazards. • Storage bays must be appropriately marked with the HW in storage.
7.4. Labeling and Marking Containers used for the accumulation and transportation of HW must be properly identified with a Hazardous Waste marker and an appropriate hazard class label (flammable, corrosive, etc.) at all times from the start of accumulation to ultimate disposal IAW applicable laws and regulations. The Hazardous Waste marker will include a description of the contents of the container in the form of a Proper Shipping Name (PSN) as established in the waste characterization process and used on the waste manifest which accompanies the container to the ultimate disposal site (either paper or approved electronic form).
When transporting HW via commercial transportation on public road and highways, HW generators will prepare off-installation HW shipments in compliance with DoD Component Policies. Requirements may include placarding, marking, containerization, and labeling. Hazardous Waste designated for international transport will be prepared in accordance with the documents listed above and applicable international regulations.
EESOH-MIS, Hazardous Waste Module has a version of the HW label that can be customized (i.e., Host Nation (HN) language) and utilized. Installation Supplement – Labeling and Marking
Hazardous Waste Accumulation Points (HWAPs)
Labels
Every active HW container at an HWAP must have a correct and complete HW label.
• Labels are generated and provided by the HWSA and are delivered with containers to the HWAPs. • The HWAPs are responsible for maintaining the label on each container.
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• The HWAPs must contact 48 CES/CEIE immediately if a container is missing the required label. • Labels must be securely adhered to the container and placed so that they are clearly visible at all times upon approach to the HWAP and to anyone placing waste in the container. • Labeling information must remain legible at all times.
Placards
Placards or hazard diamonds are required for items that have a PSN and are regulated for transport on the roadways.
• The HWSA will provide the HWAPs with the appropriate hazard diamond sticker for each container. • The HWAPs are responsible for maintaining the hazard diamond sticker on each container. • The HWAPs must contact 48 CES/CEIE immediately if a container is missing the required hazard diamond. • The hazard diamond should be placed near the HW label on the container and should be visible upon approach to the HWAP.
7.5 Hazardous Waste Management An HWAP may be used to accumulate no more than 208 liters (55 gallons) of HW, or 1 liter (1 quart) of acute HW, from each waste stream. When these limits have been reached, the generator will make arrangements within five (5) working days to move the HW to an HWSA or ship it off-site for treatment or disposal. Hazardous waste should not be stored longer than one (1) year in an HWSA. Wastes intended to be recycled or used for energy recovery (e.g., used oil or antifreeze) are exempt from the 208-liter (55-gallons)/1-liter (1-quart) volume accumulation limits, but must be transported off-site to a final destination facility within one (1) year.
Installation Supplement – Hazardous Waste Management
Hazardous Waste Accumulation Point Operating Procedures The HWAP Monitor and Alternate assume overall responsibility for management of the HWAP. Details on the overall management of the HWAP are outlined in Section 4.0, Roles and Responsibilities of the HWAP Manager and Alternate. The previously discussed waste identification (Section 7.2), container management and containment requirements (Section 7.3) and labeling and marking (Section 7.4) also apply to HWAP operations. Furthermore, there are additional record keeping and reporting requirements (Section 6.0) relevant to HWAP operations also previously discussed. Other specific requirements for HWAPs are listed below:
• The HWAP must be at or near the point of generation. • The HWAP must be under the control of the unit managing it. Authorized site security measures include constant monitoring, a locked storage unit, or locked containers. • The HWAP must be designed and operated to provide appropriate segregation for different waste streams, including those that are chemically incompatible. • Each HWAP is required to have a portable fire extinguisher and an emergency eyewash station,
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PPE, and a spill kit with adequate materials for the type of HW stored. The spill kit must contain an adequate amount of appropriate spill materials for items accumulated on site or any potential spill from facility operations. For example, if corrosive liquid is accumulated on site, spill absorbents made for corrosives must be present. The purchase of spill kits and materials is the responsibility of the user. • Signage for the HWAP must be visible from 25 ft. Information on the sign must be kept updated. The HWAP sign should include the HWAP assigned number, the HWAP shop’s phone number, and the emergency phone number. • The HWAP Monitor submits requests to the HWSA Manager via telephone at DSN 226-5352 to pick up full containers and should expect containers to be collected within five working days. The HWSA Manager will replace the full containers with empty containers that are labeled to accept the same waste as the full container.
Establishment of HWAPs
Any organization on base that determines its activities will generate HW must contact 48 CES/CEIE to establish an HWAP in advance of waste generation.
• The operator must contact 48 CES/CEIE and 48 CES/CEF to allow these offices an opportunity to inspect the proposed HWAP location. 48 AMDS/SGPB and 48 FW/SEG will be notified of new or changed HWAP locations. • HWAP monitors or supervisors must notify the offices listed above if moving an accumulation point or a waste stream. • Each waste-generating functional area shall appoint a primary and alternate site manager for each HWAP and/or accumulation site. • All HW must be within the control of a responsible, trained party. The waste must be placed into the appropriate HWAP container in a timely manner, but no later than the end of the shift.
Hazardous Waste Storage Area Operating Procedures
The only HWSA for RAF Lakenheath and RAF Feltwell is located at Building 1218, RAF Lakenheath. The previously discussed waste identification (Section 7.2), container management requirements (Section 7.3) and labeling and marking (Section 7.4) all apply to HWSA operations as well as record keeping requirements (Section 6.0). There are other more rigorous requirements for HWSAs as listed below:
• Communications. An internal communications or alarm system capable of providing immediate emergency instructions (voice or signal) to HWSA personnel must be available. The HWSA is currently equipped with a fire alarm system and a telephone. • Emergency Equipment. Portable fire extinguishers, fire control equipment appropriate to the material in storage, spill control equipment and decontamination equipment must be available on site. • Water Supply. Water with adequate volume and pressure must be available on site. • Eyewash and Shower. Eyewash and shower facilities must be on site. • Personnel Protective Equipment. An adequate amount of PPE of the appropriate size and type must be readily available. • Security. The facility entrance gate at the HWSA is kept locked when personnel are not present. The HWSA consists of lockable units. Any unit storing HW must be locked when not in use.
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• Signage. “Danger Unauthorized Personnel Keep Out” signs must be posted at each entrance to the HWSA and visible from at least 25 feet. • "No Smoking" signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste. • If there is only one person on duty at the HWSA premises, that person must have immediate access to a device, such as a telephone (immediately available at the scene of operation) or a hand held two way radio, capable of summoning external emergency assistance.
Hazardous Waste Storage Area Closure Plan
A closure plan has been developed for the RAF Lakenheath HWSA (Appendix C). The closure plan will be implemented in the future if a decision is ever made to close the HWSA at Building 1218.
7.6 Transportation The 48 CES/CEIE HW Program Manager has overall responsibility for the transportation of HW from an HWAP to an HWSA, and from an HWSA to the disposal facility. The 48 CES/CEIE HW Program Manager ensures:
• All transportation over HN public roads is conducted IAW applicable HN or international transportation regulations. • Containers are approved. • Transporters have the appropriate training. • Uniform Hazardous Waste Manifests are prepared for offsite transportation. • All necessary documentation has been completed and records are maintained IAW all applicable requirements and the AF Records Disposition Schedule.
Installation Supplement – Transportation
Hazardous Waste (HW) Transport from RAF Feltwell to RAF Lakenheath HWSA
Hazardous wastes should never be transported from RAF Feltwell to RAF Lakenheath. Generation of HW at RAF Feltwell should be coordinated with 48 CES/CEIE to establish an HWAP and ensure proper storage. 48 CES/CEIE will coordinate pickups and shipments of HW from RAF Feltwell with DLA-DS and an authorized HW transporter.
7.7 Turn In/Disposal The turn-in procedures are contained in DoD 4160.12-M. DLA Disposition Services are followed. In the event an alternate route for disposal is needed, a waiver will be obtained with proper justification and approval. Containers are inspected, prior to turn-in, to ensure that container management procedures have been followed and that containers are properly labeled and in good condition. If the container is not in good condition, contents are transferred to a container that is in good condition.
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Installation Supplement – Turn In/Disposal
Hazardous Waste Accumulation Points (HWAPs)
Turn-In and Disposal from HWAPs
All HAZMAT and HW are removed to the HWSA on a pick-up basis by HWSA personnel.
• To schedule a removal, contact the HWSA at 226-5352 or the 48 CES/CEIE HW Program Manager at 226-3990. The full container will be removed within five working days. • HWAP Monitors must be aware of the status of their drums and schedule pick-ups accordingly. • Proper documentation must be provided at the time of waste removal. A profile number for recurring waste streams or an SDS for expired or unusable HAZMAT must be provided. • Unknown items will remain at the HWAP marked with ‘pending analysis’ and the date the sample was taken until sample results are returned and the waste is properly characterized. The procedures in Appendix A must be followed to request a HW review of unknown items. • HWAPs must ensure maximum reuse of HAZMAT prior to disposal.
Hazardous Waste Storage Area (HWSA) Disposal
• 48 CES/CEIE HW Program Manager processes removal orders in EESOH-MIS, coordinates with DLA-DS contractor, and schedules pickup. • On day of pickup, all three (3) agencies must be present: DLA-DS, 48 CES/CEIE HW Program Manager, and DLA-DS contractor, to verify correct declaration of labeling/loading/weighing of HW. Once correct, 48 CES/CEIE HW Program Manager can sign the HW manifest. • DLA-DS sends removal order modifications to 48 CES/CEIE HW Program Manager for corrections on final weights in EESOH-MIS. • HW manifests are sent to 48 CES/CEIE HW Program Manager for recordkeeping. • Delivery order is closed in EESOH-MIS by 48 CES/CEIE HW Program Manager.
Empty Hazardous Materials (HAZMAT) Containers
• Empty HAZMAT containers may be eligible for recycling if the container contains less than 1% product (or 0.1% of an acute HW) and the container no longer retains any hazardous properties. • Some products, because of their nature and tube-like packaging, such as sealants and adhesives, are unlikely to meet the above requirements to qualify as empty. • If unsure whether a container meets the requirements identified above, contact 48 CES/CEIE for additional information. • If empty containers are to be recycled and meet the requirements listed above, they may be turned in to the Recycling Center, Building 1140 during operating hours.
Illegal Dumping
Illegal dumping, also called fly-tipping or midnight dumping, is letting waste out of your control by depositing it outside of allowable areas. The only allowable areas for industrial HW accumulation or storage are the established HWAPs and HWSA. Waste must be accepted by personnel working at the HWAP or HWSA.
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If you witness someone leaving HW at the HWSA or placing HW in a regular trash dumpster, contact 48 SFS at DSN 226-4631.
Waste Removal by Contractors Outside of DLA Process
Additional requirements apply to units that choose a HW disposal route other than the HWSA (e.g. Safety Kleen parts washer).
• Any HW removal from RAF Lakenheath or RAF Feltwell must be accompanied by a unique consignment note that should be provided by the HW transporter. Contact 48 CES/CEIE before the scheduled waste removal to ensure the shipment has the correct information for the consignment note. • Individuals signing consignment notes must have completed appropriate training as an ADR Certifier and provide training certificate to the 48 CES/CEIE HW Program Manager. • The original consignment note must be turned into the 48 CES/CEIE HW Program Manager within two working days of waste removal. • Units can request support from 48 CES/CEIE to complete the consignment note, but must arrange this support at least 5 working days in advance. • Units must verify before releasing HW that the driver removing the waste has ADR qualifications, the vehicle transporting the waste meets applicable ADR requirements and any transfer facilities or disposal locations receiving the waste have current, appropriate licenses to handle the waste.
7.8 Inspection Inspection processes fulfill the “Check” function of the EMS “Plan, Do, Check, Act” cycle. The HWSA is inspected routinely IAW the FGS to ensure proper accumulation and container management. All other inspections occur IAW AFI 90-201, The Air Force Inspection System and the Commander’s Self Inspection Program. Inspection records are maintained IAW the Recordkeeping and Reporting section of this plan. Installation Supplement – Inspection
HWAP Inspections
HW monitors must maintain their HWAP sites in compliance with FGS and AFI requirements. A checklist is available at Appendix E – Sample Forms and Templates to aid in evaluating the HWAP for compliance.
48 CES/CEIE will direct no-notice inspections of HW generation, accumulation, storage, and disposal activities at least once per year.
HWSA Inspections
The HWSA Manager must inspect the HWSA weekly using the “HWSA Weekly Inspection Checklist” included in Appendix E – Sample Forms and Templates.
7.9 Waste Minimization Hazardous waste manifests include certification that a waste minimization program is in place. Below are key activities and processes that are performed as part of waste minimization and pollution prevention efforts:
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• Hazardous materials process authorization and HAZMAT management processes – Each process involving use of HAZMAT and generation of waste streams is evaluated and authorized. Process authorization is performed through EESOH-MIS. The 48 CES/CEIE HW Program Manager, HMMP Team and the generating activity make a final determination whether or not the results of the process authorization effort are sufficient to reduce waste toxicity and volume. • Procurement and use of minimal quantities – When a material with environmental risk must be used, minimal quantities are procured to minimize surplus quantities and shelf life exceedances. • Recycling – When the use of HAZMAT is unavoidable, excess or waste material is evaluated for reuse or recycling. • Environmental action planning – Environmental Action Plans (EAPs) are developed and maintained as part of the overall EMS. EAPs are management plans that translate environmental objectives and targets into actionable plans. Waste minimization efforts are considered during development of EAPs. Installation Supplement – Waste Minimization RAF Lakenheath utilizes an EMS to manage its environmental program, including the HW program. This system emphasizes continual improvement, which includes the focus on pollution prevention and source reduction. All HW monitors at RAF Lakenheath and RAF Feltwell are trained on pollution prevention and encouraged to communicate any ideas for further HW reductions to the 48 CES/CEIE HW Program Manager.
7.10 Preparedness and Prevention
Preparedness and prevention practices are described in emergency prevention and response plans available through the References section of this plan.
Installation Supplement – Preparedness and Prevention
Contingency Plan
Requirements for management of HAZMAT emergencies are defined in the 48 FW 32-4013, Hazardous Materials Spill Prevention and Response Plan and are maintained IAW the EMS on eDASH: Emergency Preparedness and Response, and shall include the Installation Spill Prevention and Response Plan (or equivalent) or a specific HW Contingency Plan.
Hazardous Waste Accumulation Point (HWAP) Requirements
• Shop Specific Spill Plan. Every HWAP will have a 48 CES/CEIE-approved, site specific spill plan in the format required by the 48 CES/CEIE Spill Program Manager. The plan will be prepared IAW the 48 FW Site Specific Spill Plan template and current at all times. • The template is available on eDASH: at: https://cs2.eis.af.mil/sites/10626/Lakenheath/WPP/ProgramPage/Hazardous%20Waste.as px • Spill Kit. A spill kit must be on site with all required materials.
Information and Emergency Contact Numbers
Appendix B lists emergency contact numbers in case of a HW emergency.
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7.11 Waste Specific Procedures
Waste-specific procedures are included in the installation supplement below or maintained as separate operational controls outside of this plan.
Installation Supplement – Waste Specific Procedures
Reclaimable/Waste JP-8 Fuel
In an effort to minimize waste JP-8 fuel disposal, the 48 FW operates the following procedures to test fuel bowser contents and reclaim unused fuel to the maximum extent possible:
48 FW Fuel Bowsers User Responsibilities
• Position bowsers in user’s designated bowser storage location. Set parking brake and attach grounding clip to earth ground strip. • Indicate date, time, and unit number on placard to verify sufficient settling time. • User should contact the Maintenance Operations Command (MOC) at DSN 314-226-3119 upon completion of an eight (8) hour settling period. NOTE: Bowser is required to sit for a minimum of eight (8) hours to allow for water/particulate to settle out of the fuel. • The user will remove water/particulate. Any drained waste water should be managed and disposed as HW. Contact the 48 CES/CEIE HW Program Manager (226-3990) or the HWSA (226-5352) for collection and disposal instructions. • Once the settling period has passed and the contaminants have been removed, MOC will contact the Fuels Service Center (FSC) at DSN 314-226-3119 and request a sample be drawn and tested by Petroleum, Oils, and Lubricants (POL) laboratory personnel. • If tests are within criteria, POL will approve the product for reclamation via checklist AF IMT 2519 and seal the bowser(s). The user will tow bowser to Facility 1910 fuel off-loading headers. A POL equipment operator will reclaim the fuel should the second sample pass visual inspection. • If product is determined un-reclaimable, user will coordinate for disposal with the HWSA at 226- 5352. Upon coordination user will tow bowser to the HWSA (Bldg. 1218). NOTE: User must provide AF IMT 2519 for coordination and disposition of waste fuel. • Users will remove the bowser from the HWSA upon notification that the bowser has been emptied of waste. • Maintain fuel bowser lock keys for all assigned bowsers in each Aircraft Maintenance Unit Support Sections to ensure positive accountability for all products introduced into the bowser.
48 Logistics Readiness Squadron POL Responsibilities
• Draw fuel samples when requested from bowsers at the 48th Equipment Maintenance Squadron Aerospace Ground Equipment (AGE) Service Station, Component-Maintenance Squadron (CMS) Fuel Cell Facility, or locations where product has been allowed to settle for the required eight hours • Test fuel to determine quality IAW Technical Order 42B-1-1, Appendix C, para C.1.4. • If product is determined to be reclaimable, annotate AF IMT 2519, and seal bowser. • Upon bowsers arrival to Facility 1910, verify seal(s), and reclaim product.
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• Credit applicable Aircraft Maintenance Squadron for reclaimed fuel.
Unused Product Turn-Ins
Hazardous materials that are unused and still have shelf life that shops no longer require should be turned back in to Logistics Readiness Squadron (LRS) Hazmart for the free issue program. Hazardous materials that are unused and cannot be extended should be dispositioned through EESOH-MIS. To arrange for pickup, call the HWSA at 226-5352 and the shop shall provide SDS at time of pickup for the material.
Household Hazardous Waste (HHW)
Definition
Household hazardous wastes are produced at residential locations, which include, but are not limited to, automotive oil, batteries, paints, household cleaners, computer monitors and televisions.
Industrial versus Household Wastes
• Wastes generated at the workplace must be kept at the workplace and not taken home for disposal, just as wastes generated at the household must be kept at the household and not taken to work for disposal. • Even if identical wastes are generated at the workplace and the household, such as used oil, the laws and regulations governing the disposal of these items are different.
Disposal
• The HWSA is only for industrial waste disposal and cannot accept wastes generated from households. • For disposal of HHW, the resident’s local host nation council must be contacted. The Household Waste Disposal site off A1065 near Mildenhall takes many household hazardous items. Contact the Household Waste facility at 03456 066 067 or go to their website at: http://www.greensuffolk.org/recycling/HWRC.
Waste Electrical and Electronic Equipment (WEEE)
Definition
Waste electrical and electronic equipment are items that require electric currents or electromagnetic fields to function.
• Waste electrical and electronic equipment include large and small appliances, lighting equipment, electric tools, toys and leisure equipment. For more information, contact the 48 CES/CEIE HW Program Manager at 226-3990. • Not all WEEE is considered HW for disposal.
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Waste Electrical and Electronic Equipment – Industrial
• Hazardous WEEE-Industrial • Televisions and computer monitors with Cathode Ray Tubes (CRTs) are considered HW for disposal. • Refrigerators and refrigeration equipment produced prior to 2002 are considered HW for disposal. • Only items refused by DLA-DS for reuse will be accepted for disposal. • Exemptions for WEEE requirements exist for items that are connected with the protection of the essential interests of security such as arms, munitions, war materials and items that are intended for specific military purposes or national security. • Non-Hazardous WEEE-Industrial • Non-hazardous WEEE can be turned in to DLA-DS or recycled through the base recycling program.
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8.0 REFERENCES
Standard References (Applicable to all AF Installations)
• ADLS – Advanced Distributed Learning Service • AFI 32-7001, Environmental Management • AFMAN 32-7002, Waste Management • AFMAN 32-7002, Hazardous Materials Management • AFI 90-201, The Air Force Inspection System • AFLOA HW Legal and Other Requirements – The Air Force Legal Operations Agency (AFLOA) legal registry lists and provides access to Final Governing Standards, DoD, AF and other legal requirements" • DoD 4160.21-Volume 4, Defense Materiel Disposition Manual: Instructions for Hazardous Property and Other Special Processing Materiel • EASIER Database • eDASH Hazardous Waste Environmental Action Plans (EAPs) • eDASH Hazardous Waste Home Page • eDASH Hazardous Waste Training Matrix • EESOH-MIS Software Module • Hazardous Waste Playbook
Installation References
• Final Governing Standards for the United Kingdom (FGS-UK) 08 Jan 2018 • 48 FW 32-4013 Hazardous Materials Spill Prevention and Response Plan
9.0 ACRONYMS
Standard Acronyms (Applicable to all AF Installations)
• eDASH Acronym Library • Hazardous Waste Playbook – Acronym Section
Installation Acronyms
• ADR – European Agreement Concerning the International Carriage of Dangerous Goods by Road • AFIMSC Det 4 – Air Force Installation & Mission Support Center Detachment 4 • BR – Business Rule • CEIE – Civil Engineering Installation Management Environmental • CRT – Cathode Ray Tube • CZ – AFCEC Environmental • DIO – Defense Infrastructure Organization • DLA-DS – Defense Logistics Agency Disposition Services • EWC – European Waste Catalogue • FGS-UK – Final Governing Standards – United Kingdom • HHW – Household Hazardous Waste • HWSA – Hazardous Waste Storage Area
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• MOC – Maintenance Operations Command • RAF – Royal Air Force • SDS – Safety Data Sheet • USEUCOM – United States European Command • UK – United Kingdom • WAP –Waste Analysis Plan • WEEE – Waste Electrical and Electronic Equipment • WMS – Waste Management Services • EESOH-MIS – Enterprise Environmental Safety Occupational Health-Management Information system
10.0 DEFINITIONS
Standard Definitions (Applicable to all AF Installations)
• Hazardous Waste Playbook – Definitions Section
11.0 INSTALLATION-SPECIFIC CONTENT
Installation-specific content is captured in previous sections of this document.
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APPENDICES
Appendix A – Waste Analysis Plan
A1. BACKGROUND A1.1. About This Plan This installation-specific Waste Analysis Plan (WAP) is required by AFMAN 32-7002 and the various Final Governing Standards (FGS) applicable to United States Air Forces Europe (USAFE) installations. This plan is not an inventory of all hazardous waste analysis procedures. It is intended to be a baseline guide for determining the presence/absence of hazardous waste (HW) and a general outline for disposing of HW using the Defense Logistics Agency Disposition Services (DLA-DS) contract framework. It also provides procedures for identifying and evaluating HW streams in order to complete a Hazardous Waste Profile Sheet (HWPS) (DRMS Form 1930) for each stream. Each section of the WAP begins with standard “common text” language that applies to all USAFE installations. To ensure consistency across all USAFE WAPs, the common text should not be edited and is maintained by Environmental and Real Property Branch, Air Force Installation and Mission Support Center Detachment 4, Civil Engineering Installation Management Environmental (AFIMSC Det 4/CEIE). Immediately following the common text are sections for installation-specific content to address local requirements and procedures. Installation sections are maintained by the installation environmental office.
A1.2. Regulatory Requirements The WAP applies to all HW streams generated at the installation, tenant units, and/or geographically separated units (GSUs) that have agreements that designate the installation as HW stream administrator.
According to the FGS, at a minimum, the WAP must include: • Parameters for testing and rationale for choosing them (see section 2, Detailed Definition of Hazardous Waste, and section 4, Waste Characterization) • Frequency of analysis (see section 7, Analysis Frequency) • Test methods (see section 5, Waste Characterization) • Sampling methods (see section 3, Waste Sampling Procedures)
A2. DETAILED DEFINITION OF HAZARDOUS WASTE
Within the United States European Command (USEUCOM), hazardous waste is defined as follows:
Hazardous Waste is a waste that may be solid, semi-solid, liquid, or contained gas that is either listed as a 6-digit waste code and marked with an asterisk in the USEUCOM Waste List or the European Waste Catalogue (EWC), but without a specific or general reference to “dangerous substances;” or
…listed as a 6-digit waste code and marked with an asterisk in the USEUCOM Waste List or the European Waste Catalogue (EWC) with a specific or general reference to “dangerous substances” and presents one or more hazardous properties listed in Table WAP-T1, “Hazardous Properties.”
The tables below are adapted from the FGS Chapter 6 - Hazardous Waste and Annex III to Directive 2008/98/EC.
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WAP-T1 – Hazardous Properties
Hazard Class and Hazard Hazardous Properties Descriptions Category Code(s) Code(s) Unst. Expl. H200 Expl. 1.1 H201 HP 1“Explosive:” Waste which is capable by chemical reaction of producing gas at such a Expl. 1.2 H202 temperature and pressure and at such a speed as to cause damage to the Expl. 1.3 H203 surroundings. Pyrotechnic waste, explosive organic peroxide waste and Expl. 1.4 H204 explosive self-reactive waste is included. If the presence of a substance or laboratory testing indicates that the Self-react. A Org. Perox. A H240 waste is explosive, it shall be classified as hazardous by HP 1. Self-react. B Org. Perox. B H241
Ox. Gas 1 H270
HP 2“Oxidizing:” Ox. Liq. 1 Waste which may, generally by providing oxygen, cause or contribute to H271 the combustion of other materials. Ox. Sol. 1 If the presence of a substance or laboratory testing indicates that the waste is oxidizing, it shall be classified as hazardous by HP 2. Ox. Liq. 2, Ox. Liq 3 H272 Ox. Sol 2, Ox. Sol 3 Flam. Gas 1 H220 Flam. Gas 2 H221 Aerosol 1 H222 HP 3“Flammable:” Aerosol 2 H223 Flammable liquid waste: liquid waste having a flash point below 60 °C or waste gas oil, diesel and light heating oils having a flash point >55 °C Flam. Liq. 1 H224 and ≤75 °C; Flam. Liq. 2 H225 Flammable pyrophoric liquid and solid waste: solid or liquid waste which, even in small quantities, is liable to ignite within 5 minutes after Flam. Liq. 3 H226 coming into contact with air; Flam. Sol 1 H228 Flammable solid waste: solid waste which is readily combustible or may Flam. Sol 2 cause or contribute to fire through friction; Self-react. CD Flammable gaseous waste: gaseous waste which is flammable in air at 20 Self-rect. EF °C and a standard pressure of 101.3 kPa; H242 Water reactive waste: waste which, in contact with water, emits Org. Perox. CD flammable gases in dangerous quantities; Org. Perox. EF Other flammable waste: flammable aerosols, flammable self-heating Pyr. Liq. 1 waste, flammable organic peroxides and flammable self-reactive waste. H250 If the presence of a substance or laboratory testing indicates that the Pyr. Sol. 1 waste is flammable, it shall be classified as hazardous by HP 3. Self-heat. 1 H251 Self-heat. 2 H252 Water-react. 1 H260 Water-react. 2 H261
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Hazard Class and Hazard Hazardous Properties Descriptions Category Code(s) Code(s)
HP 4 “Irritant - skin irritation and eye damage:” Waste which on application can cause skin irritation or damage to the eye. When a waste contains one or more substances in concentrations above the cut- off value, that are classified by one of the following hazard class and category codes and hazard statement codes and one or more of the following concentration limits is exceeded or equaled, the waste shall be classified as hazardous by HP 4. The cut-off value for consideration in an assessment for Skin corr. 1A Skin corr. 1A (H314), Skin (H314), Skin irrit. 2 (H315), Eye dam. 1 (H318) and Eye irrit. 2 (H319) is irrit. 2 (H315), Eye dam. 1 1%. (H318) and Eye irrit. 2 H314, H315, If the sum of the concentrations of all substances classified as Skin corr. (H319) per conditions in H318, H319 1A (H314) exceeds or equals 1%, the waste shall be classified as column to the left hazardous according to HP 4.
If the sum of the concentrations of all substances classified as H318 exceeds or equals 10%, the waste shall be classified as hazardous according to HP 4. If the sum of the concentrations of all substances classified H315 and H319 exceeds or equals 20%, the waste shall be classified as hazardous according to HP 4. Note that wastes containing substances classified as H314 (Skin corr.1A, 1B or 1C) in amounts greater than or equal to 5% will be classified as hazardous by HP 8. HP 4 will not apply if the waste is classified as HP 8.
STOT SE 1; concentration limit 1% SE H370 HP 5 “Specific Target Organ Toxicity (STOT)/Aspiration Toxicity:” = single exposure Waste which can cause specific target organ toxicity either from a single STOT SE 2; or repeated exposure, or which cause acute toxic effects following H371 aspiration. concentration limit 10% When a waste contains one or more substances classified by one or more STOT SE 3; of the following hazard class and category codes and hazard statement H335 concentration limit 20% codes shown in Table 4, and one or more of the concentration limits in Table 4 is exceeded or equaled, the waste shall be classified as hazardous STOT RE 1; according to HP 5. When substances classified as STOT are present in a concentration limit 1% RE H372 waste, an individual substance has to be present at or above the = repeated exposure concentration limit for the waste to be classified as hazardous by HP 5. When a waste contains one or more substances classified as Asp. Tox. 1 STOT RE 2; H373 and the sum of those substances exceeds or equals the concentration concentration limit 10% limit, the waste shall be classified as hazardous by HP 5 only where the overall kinematic viscosity (at 40 °C) does not exceed 20.5 mm2/s. Asp. Tox. 1; concentration limit 10% H304 ASP. = aspiration
HP 6“Acute Toxicity:” Acute Tox. 1. (Oral), H300 Waste which can cause acute toxic effects following oral or dermal concentration limit 0.1% administration, or inhalation exposure. If the sum of the concentrations of all substances contained in a waste, Acute Tox. 2 (Oral), H300 classified with an acute toxic hazard class and category code and hazard concentration limit 0.25% statement code, exceeds or equals the threshold given, the waste shall be
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Hazard Class and Hazard Hazardous Properties Descriptions Category Code(s) Code(s) classified as hazardous by HP 6. When more than one substance Acute Tox. 3 (Oral), H301 classified as acute toxic is present in a waste, the sum of the concentration limit 5% concentrations is required only for substances within the same hazard Acute Tox. 4 (Oral), category. H302 The following cut-off values shall apply for consideration in an concentration limit 25% assessment: Acute Tox. 1 (Dermal), - For Acute Tox. 1, 2 or 3 (H300, H310, H330, H301, H311, H331): H310 0.1%; concentration limit 0.25% - For Acute Tox. 4 (H302, H312, H332): 1%. Acute Tox. 2 (Dermal), H310 concentration limit 2.5% Acute Tox. 3 (Dermal), H311 concentration limit 15% Acute Tox. 4 (Dermal), H312 concentration limit 55% Acute Tox. 1 (Inhal.), H330 concentration limit 0.1% Acute Tox. 2 (Inhal.), H330 concentration limit 0.5% Acute Tox. 3 (Inhal.), H331 concentration limit 3.5% Acute Tox. 4 (Inhal.), H332 concentration limit 22.5%
HP 7“Carcinogenic:” Carc. 1A, Waste which induces cancer or increases its incidence. When a waste concentration limit 0.1% contains a substance classified by one of the following hazard class and H350 category codes and hazard statement codes and exceeds or equals one of Carc. 1B, the following concentration limits shown in column 2, the waste shall be concentration limit 0.1% classified as hazardous by HP 7. When more than one substance classified as carcinogenic is present in a Carc. 2, Suspected human waste, an individual substance has to be present at or above the carcinogens H351 concentration limit for the waste to be classified as hazardous by HP 7. Concentration limit 1%
HP 8“Corrosive:” Waste which on application can cause skin corrosion. When a waste contains one or more substances classified as Skin corr.1A, 1B or 1C (H314) and the sum of their concentrations exceeds or equals See HP4 5%, the waste shall be classified as hazardous by HP 8. The cut-off value for consideration in an assessment for Skin corr. 1A, 1B, 1C (H314) is 1.0%.
HP 9“Infectious:” Waste containing viable micro-organisms or their toxins which are known or reliably believed to cause disease in man or other living organisms.
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Hazard Class and Hazard Hazardous Properties Descriptions Category Code(s) Code(s)
HP 10“Toxic for reproduction:” Repr. 1A; Waste which has adverse effects on sexual function and fertility in adult concentration limit 0.3% males and females, as well as developmental toxicity in the offspring. H360 When a waste contains a substance classified by one of the following hazard class and category codes and hazard statement codes and exceeds or equals one of the following concentration limits shown in column 2, Repr. 1B; the waste shall be classified hazardous according to HP 10. When more concentration limit 0.3% than one substance classified as toxic for reproduction is present in a waste, an individual substance has to be present at or above the Repr. 2; concentration limit for the waste to be classified as hazardous by HP 10. H361 Concentration limit 3.0%
HP 11“Mutagenic:” Muta. 1A, Waste which may cause a mutation, which is a permanent change in the concentration limit 0.1% amount or structure of the genetic material in a cell. H340 When a waste contains a substance classified by one of the following Muta. 1B, hazard class and category codes and hazard statement codes and exceeds concentration limit 0.1% or equals one of the following concentration limits shown in column 2, the waste shall be classified as hazardous according to HP 11. When more than one substance classified as mutagenic is present in a waste, an Muta. 2, individual substance has to be present at or above the concentration limit H341 for the waste to be classified as hazardous by HP 11. concentration limit 1.0%
HP 12“Release of an acute toxic gas:” Waste which releases acute toxic gases (Acute Tox. 1, 2 or 3) in contact EUH029, with water or an acid. EUH031, When a waste contains a substance assigned to one of the following EUH032 supplemental hazards EUH029, EUH031 and EUH032, it shall be classified as hazardous by HP 12 according to test methods or guidelines.
HP 13“Sensitizing:” Waste which contains one or more substances known to cause sensitizing effects to the skin or the respiratory organs. H317, When a waste contains a substance classified as sensitizing and is H334 assigned to one of the hazard statement codes H317 or H334 and one individual substance equals or exceeds the concentration limit of 10 %, the waste shall be classified as hazardous by HP 13.
Toxic acute 1 H400 Chronic 1 H410 HP 14“Ecotoxic:”waste which presents or may present immediate or Chronic 2 H411 delayed risks for one or more sectors of the environment. (See Chapter 5 Chronic 3 H412 of these FGS) Chronic 4 H413 Ozone Depleting H420
HP 15“Waste capable of exhibiting a hazardous property listed May explode in fire H205 above not directly displayed by the original waste”. Explosive when dry EUH001
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Hazard Class and Hazard Hazardous Properties Descriptions Category Code(s) Code(s) When a waste contains one or more substances assigned to one of the May form explosive EUH019 hazard statements or supplemental hazards shown to the right, the waste peroxides shall be classified as hazardous by HP 15, unless the waste is in such a form that it will not under any circumstance exhibit explosive or Risk of explosion if heated EUH044 potentially explosive properties. under confinement
A3. WASTE SAMPLING PROCEDURES When HW sampling is required, the installation 48 CES/CEIE HW Program Manager contacts the DLA- DS contractor to send a representative to collect the sample.
Samples must be placed in lab-approved containers provided by the DLA-DS contractor.
The sample collector must complete the “field portion” of a sample analysis request form to accompany the sample to the laboratory. Sample analysis forms are typically provided by the lab that will analyze the sample. The “field portion” typically requires information such as the sample number, the requested analysis, and the name and phone number of the person collecting the sample.
Lab professionals complete the “laboratory portion” of the from which often includes the person’s name receiving the sample, laboratory sample number, date and time of sample receipt, and analysis to be performed.
Installation Supplement – Waste Sampling Procedures
The following sampling procedures will be followed when collecting samples for HW analysis and characterization:
• Sampling equipment and sample bottles will be clean to prevent sample contamination • Sample bottles are obtained directly from authorized suppliers to the United Kingdom Accreditation Service (UKAS) laboratory and are used as received • Sample bottles or vials intended for holding samples that await analysis for volatile organic compounds will be filled until there is no headspace. Once filled, they will be placed in a cooler and covered with ice to ensure that they are cooled to 4°C • Sampling equipment will be de-contaminated prior to re-use by washing it in a detergent solution followed by rinsing. Disposable sampling equipment (e.g., a disposable dipper) will be properly disposed after sample collection • Personnel who collect HW samples will wear personal protective equipment (PPE) including impervious gloves, chemical safety goggles, coveralls and suitable boots. A minimum of Level B protection (e.g., chemical splash suit, impervious gloves, impervious outer boots and a positive pressure self-contained breathing apparatus) will be worn when sampling unknown wastes • Only properly trained personnel will perform sampling. • Obtaining samples of unknown wastes: . Safety Precautions. The first phase of obtaining samples of unknown waste is to eliminate any immediate hazard . Isolate the area, restrict personnel access and contain any leaks or spills
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. Required protective clothing should be identified as well as any equipment specifications such as the use of non-sparking tools . A bulging drum indicates that it is under pressure and should not be sampled until pressure is relieved. These situations must be coordinated with the 48 CES/CEF and other appropriate emergency response organizations • Initial Screening: Record conditions, markings and observations of containers and include background information obtained from record searches or personnel interviews. The following information describing the physical characteristics of the waste should be recorded: . Color. Describe the color of the waste (e.g., blue, clear, varies) . Physical State (e.g., solid, liquid, powder, gas, semi-solid or sludge) . Layers. Note whether the waste is multi-layered (e.g., oil/water/sludge), bi-layered (e.g., oil/water) or homogeneous . Percent Liquid. Estimate the percent of liquid volume. The Pressure Filtration or Paint Filter • Test may be conducted to confirm there are no free flowing liquids
A4. SAMPLE DOCUMENTATION
The installation HW Program Manager must ensure that the DLA-DS contractor uses proper sample labels, analysis request forms, and chain of custody forms for all shipments to ensure the integrity of sample collection.
The DLA-DS contractor will place sample labels on containers prior to sampling. Labels will only be filled out at the time of sample collection.
Information on the label will include the sample number, name of sampler, date, time and place of collection. The DLSDS contractor will complete a chain of custody record, which accompanies every sample.
At a minimum, the following information will be recorded by the DLA-DS contractor when waste is collected:
• Type of waste collected, location, and number of sample containers • Names and signatures persons performing the sampling • Sample number, identification, date and time of collection, and designation as a grab or composite • Parameters to be analyzed by the laboratory • Names and signatures of any persons involved in transferring samples • If applicable, the shipping (air bill) number for samples shipped to off-site laboratories • Up-to-date sample log
Upon delivery of the chemical analysis report, the DLA-DS contractor must obtain the installation HW Program Manager signature on the appropriate form to confirm that the services have been received and that a copy of the analytical report was provided.
The results of the chemical analysis should be retained by the installation HW Program Manager, and used to aid in the completion of the HWPS (see section 6 Hazardous Waste Profile Sheet) in EESOH- MIS.
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Records of chemical analysis must be retained until 3 years after the closure of the HWSA.
Installation Supplement – Sample Documentation
None
A5. WASTE CHARACTERIZATION
The installation must identify and characterize waste based on their knowledge of the materials and processes that generated the waste or based on a laboratory analysis of the waste.
Installations must identify inherent hazardous characteristics associated with waste in terms of physical properties (e.g., solid, liquid, contained gases), chemical properties (e.g., chemical constituents, technical or chemical name), and/or other descriptive properties (e.g., hazardous properties identified in the EWC).
Defining characteristics must be measurable by standardized and available testing protocols.
All new waste streams must be evaluated as soon as they are generated – prior to leaving the shop where generated – to determine whether the process has resulted in potential HW. Analytical testing is required for wastes that are chemical mixtures or unknowns. The installation’s HW Program Manager can assist if shop-level personnel need assistance.
HW characterization involves two steps:
A5.1. Step 1 - Waste Identification The installation HW Program Manager should ask the following questions to determine if a waste stream must be evaluated:
Is it a waste? The material is a waste if the answer to any of the following questions is “yes”:
• Is the material no longer useful for its intended purpose because it is dirty or out of specification? • Is the material an unintended or unusable byproduct? • Does the installation intend to discard the material for eventual treatment, storage, recycling, or disposal? • Is the material produced by cleanup of a previously uncontrolled waste site?
Is it a hazardous waste? Refer to Section 2, Detailed Definition of Hazardous Waste. Please note that the FGS does NOT contain criteria for the four types of wastes categorized as “universal wastes” (i.e., batteries, pesticides, mercury- containing equipment and mercury lamps) by the US Resource Conservation and Recovery Act (RCRA). Each waste stream that would be considered a “universal waste” in the US must be evaluated against the FGS definition of HW. For example, used fluorescent tubes at USAFE installations are considered HW because they are assigned a six digit waste code marked with an asterisk on the USEUCOM Waste List (20 01 21* fluorescent tubes and other mercury-containing waste).
If the shop cannot immediately determine if the waste is hazardous, then the installation HW Program Manager can assist. In the event that determination remains unclear, analytical testing can be performed
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by DLA-DS contractor using the contract line item number (CLIN) for “unknown analysis” (N66000).
All potentially hazardous, but as yet uncharacterized, waste must be managed as HW.
Is it managed under the installation’s Qualified Recycling Program? Certain recyclable waste streams such as used oil and lead-acid batteries have economic value and may be collected and recycled as part of the installation’s Qualified Recycling Program (QRP). Refer to the installation supplement at the end of this section to determine if special waste analysis procedures are in place for certain recyclable waste streams under the QRP.
A5.2. Step 2 - Hazard Determination
The Safety Data Sheet (SDS) or MSDS (in the case of older materials) that matches the formulation of the material received should be reviewed to determine if a waste stream is hazardous. Review should include, but is not limited to, hazards identification, hazard statements/pictograms, composition/ingredients, and disposal considerations sections. Such review – combined with the installation’s knowledge and/or analytical results – help determine whether the waste is hazardous.
A5.3. Results Interpretation The DLA-DS contractor will provide hazard determination results, an EWC code, and generally a recommended CLIN for paying for the disposal.
If results determine that the waste is not HW, its container should be labeled in accordance with host nation requirements for the equivalent of US non-regulated waste.
A5.3.1. Identifying Unknown Waste Streams If it cannot be determined by shop-level personnel and/or an SDS review, the installation HW Program Manager is required to secure analytical test results to determine if a material is HW.
When officially requested, the DLA-DS contractor will provide all services, property, supplies, furnishings and equipment necessary to conduct the required test(s) of selected waste/materials.
A5.3.1.1. Initial Unknown Waste Stream Analysis Step One: When waste of unknown composition needs to be identified for the purpose of completing a HWPS, a Disposal Turn In Document (DTID) (DD Form 1348 1A) should be generated requesting an “unknown analysis” using CLIN N66000.
The installation must provide all the information it has available (e.g. product trade names, product identifiers, manufacturer name and contact information, National Stock Numbers (NSN)) concerning the material prior to sample collection by the DLA-DS contractor.
When CLIN N66000 is ordered, the analysis will include: (1) Ignitability (2) Reactive assessment (3) pH test (4) Qualitative analysis for Total Metals (5) Qualitative analysis for Total Pesticides (6) Qualitative analysis for Total Organic compounds
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The DLA-DS contractor will collect a sample of sufficient quantity to perform all tests and any additional testing that may be necessary to identify the material in order to complete the HWPS. Samples will be collected following host nation protocols for sample collection, sample storage, and chain of custody procedures. Samples will be collected in DLA-DS contractor-supplied and laboratory-approved containers.
If the installation suspects that the waste may include contamination not identified by the tests listed above (e.g. PCB, asbestos, etc.), then the Installation HW PM must separately order additional lab analysis (see HW Disposal Contract for list of all available waste characterization CLINs). If tests do not indicate the presence of metals, pesticides, or organic compounds, the DLA-DS contractor will complete the HWPS and consume and/or dispose of remaining sample residue. (If metals, pesticides, or organic compounds are indicated, move to step two, below.)
A5.3.1.2. Follow-up Analysis Step Two: If tests do indicate the presence of metals, pesticides, or organic compounds, the installation may use other waste characterization CLINs to order additional analysis to identify the contaminants.
When step two testing is necessary, the installation must notify the DLA-DS contractor within ten calendar days from the date the Installation HW PM received the step one analytical results.
Step two analysis may be performed on excess samples collected and/or samples that remain at the certified laboratory from the first step. If these are not options, the DLA-DS contractor may coordinate with the Installation HW PM to obtain another sample.
A5.3.2. Important Timelines The DLA-DS contractor has twenty (20) calendar days from the issuance of a written task order to complete all step one testing, analysis, and documentation. Original analytical data and chain of custody forms will be returned to the installation within 25 calendar days of the completed step one analysis.
The DLA-DS contractor has fifteen (15) calendar days to complete all step two testing, analysis, and documentation after receipt of a written task order. Original analytical data and chain of custody forms must be returned to the installation within 50 calendar days of the completed step two analysis.
Installation Supplement – Waste Characterization
The properties and hazards of any HW must be identified after generation, but prior to shipment. This process is called characterization. UK requirements differ greatly from US requirements. This characterization process is accomplished by 48 CES/CEIE.
A6. HAZARDOUS WASTE PROFILE SHEET The installation HW Program Manager is responsible for ensuring that there are appropriate HWPS forms (DRMS Form 1930) for each waste stream on the installation. To do so, the installation HW Program Manager logs into EESOH-MIS, creates a record for the waste stream, and enters specific details as prompted (see excerpt from 2.1.1 User Guide Volume IV – Hazardous Waste EESOH-MIS IT Sustainment guide below).
A waste profile can be created by clicking the button show on the Characterize Waste (Waste Profile) screen. This will display the Create Waste Profile Screen.
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Note: Waste Profile numbers (e.g., format, length, etc.) are determined by each installation. Entering the waste profile number and start date, selecting a characterization method from the pull-down menu, and clicking the Save button will display the Edit Waste Profile screen.
It is typical for the installation HW Program Manager to coordinate with and gather information from the shop-level generator as well as to consult SDSs in order complete data entry. (See Section 5 – Waste Characterization)
Once entered, the system creates the HWPS as well as the DTID and routes through DLA-DS for approval. Once approved, this process alerts HW disposal contractors of relevant precautions and restrictions.
Installation Supplement – Hazardous Waste Profile Sheet
Results from the identification process will be used to complete the HWPS required by FGS-UK, Section 6.3.1.3. The properties of the waste stream are summarized using the DRMS Form 1930 or equivalent document.
• HWPS are developed by 48 CES/CEIE in conjunction with the personnel generating the waste, including HWAP monitors. Material documentation, such as the SDS, analytical results, and the generator’s waste process knowledge will be used to complete the HWPS. All analytical results from waste evaluation activities should be attached. • DLA-DS or off-site disposal agent uses information contained on the HWPS to determine possible land disposal restrictions. 48 CES/CEIE assigns a unique reference number to each HW stream. Subsequent turn-ins of the same waste does not require a HWPS to accompany the waste. Instead, the generating activity simply places the reference number in the “Remarks” section of the DTID. • Draft waste profiles should be prepared prior to implementing new processes to ensure proper waste management practices and facilities exist for disposal. Approval for the new process must be obtained by 48 CES/CEIE. Wastes that are generated from this new process must be evaluated prior to removal from the generation site. • A master list of HWPS is maintained by 48 CES/CEIE using the Air Force EESOH-MIS system.
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A7. ANALYSIS FREQUENCY Laboratory analysis should be performed only as frequently as necessary. Lab analysis can occur periodically as a revalidation of known HW streams, or if significant modifications are made to the processes or component materials that comprise a waste stream. In this case, the installation HW Program Manager, DLA-DS manager, and shop-level generator should consult to see if new analysis is warranted.
Testing is not typically required for unused, commercial chemical products or laboratory chemicals if they are in their original, marked containers. Testing is typically also not necessary if all required information is readily available from process knowledge and an SDS or MSDS that matches the formulation of the material on hand.
Installation Supplement – Analysis Frequency
New and non-routine waste generation requires an initial analysis for the characterization of waste if components are unknown. A representative sample of unknown waste streams must be collected.
• The initial basic characterization will determine how variable a waste is and the key issues of concern. This information will dictate the frequency and scope of testing. • The HW regulations distinguish between wastes that are generated regularly in the same process and wastes that are not. There is a spectrum of waste types that ranges from regular turn-ins of constant composition to one-off turn-ins. . The ‘constant’ wastes will require less frequent characterization and more frequent testing. . ‘One-off’ wastes will effectively require basic characterization each time they occur, but little testing. . In between these extremes can be regularly generated wastes from quite variable processes or wastes that are generated infrequently that have a standard composition. • Different facilities may use identical processes and generate the same waste streams. If the characteristics of these wastes are known and key variables are shown to be the same, then wastes from only one of the facilities need to be sampled. • Additional analyses will be requested in accordance with this plan whenever the process or operation generating the HW stream has changed. • Prior to turning in a waste for disposal, the HWAP and 48 CES/CEIE must review the current HWPS to ensure it still accurately reflects the characteristics, composition and regulatory classification of the waste. This is particularly important for variable waste streams. If there has been a change in the waste stream, additional analysis and an updated HWPS may be required.
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Appendix B – Information and Emergency Contacts On Installation MAJCOM Other Contacts Contacts Contacts Fire Department 911 Command 480-8200; UK Environment 01480 01638527911 Post Agency 483658 +49-6371478200 (only CEIE personnel) Emergency Medical 911 AFIMSC/Det 4 480-0400/6099 Defence 226-5983 Care 01638527911 CEIE Infrastructure 226-1152 Organization (DIO) 226-6669 Command Post 226-4800 Off Base Incidents 999 Civil Engineer 226-2255 Customer Service Environmental 226-3990 Management Security Forces 226-4631 Bioenvironmental 226-8047 Engineering Ground Safety 226-3737 Officer Public Affairs Officer 226-2151 Contracting Officer 226-2360 Staff Judge Advocate 226-3553
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Appendix C – RAF Lakenheath HWSA Closure Plan Building 1218 serves as the Hazardous Waste Storage Area (HWSA) for RAF Lakenheath. It is managed by the 48th Civil Engineering Squadron Environmental Office.
Typical hazardous wastes (HW) stored at the facility are:
• 12 unregulated containers containing inert materials with petroleum, oil and lubricants • Flammables – UN hazard classes 3 & 4, including waste fuels, paints, and solvents • Corrosives – UN hazard class 8, including waste acids, bases, and batteries • Toxics & Miscellaneous wastes – UN hazard classes 6 and 9, including waste oils, irritants, antifreeze, and asbestos • Compressed Gases – UN hazard class 2, including oxygen, nitrogen, acetylene, argon, propane, fire extinguishers, and various refrigeration gases • Aerosols, various • Refrigerators • Other low hazard wastes generated in the normal course of operations, including contaminated soil from spills
Building 1218 consists of eight (8) bays with capacity for twenty-four 200-litre drums each, three storage lockers with capacity for thirty-two 200-litre drums each, and one storage locker with capacity for eight 200-litre drums. Therefore, the estimated HW storage capacity of Bldg. 1218 is fifty-nine 200 litres. All stored free-flowing liquids require secondary containment, provided by spill pallets and over pack drums. All wastes stored are appropriately segregated, packaged and labeled according to the FGS-UK and the RAF Lakenheath HWMP. An inventory of all HW stored at the HWSA is maintained on the Air Force EESOH-MIS HW Module and identifies contents by waste profile, UN number, hazard class and weight. A selection of empty over pack containers and drums are stored in lockers adjacent to the facility. There will be no HAZMAT/HW stored in these lockers unless clearly marked.
The estimated date for closure of the HWSA is two months after the installation closure date. Currently there is no projected closure date for the Installation. In the event of a new HWSA being constructed, the current HWSA would be kept operational until the new HWSA could be fully utilized.
Upon the announcement of a planned closure of the installation, the following steps will be taken to close the HWSA:
1. Hazardous waste will continue to be collected from the HWAP and consolidated at the HWSA for shipment off base until each HWAP is free of HW. All containers, secondary containment, signage, and other items will be removed from the HWAPs. Each HWAP will then be inspected by 48 CES/CEIE and officially closed, with a Memorandum of Record documenting the closure and kept on file. 2. All HW stored at the HWSA will be properly disposed of through the DLA-Molesworth, in accordance with the RAF Lakenheath Hazardous Waste Management Plan. 3. Any residual material/waste in each containment area will be removed, characterized, and disposed of in a manner that is appropriate for that HW. All contaminated cleaning materials, equipment and other supplies used in the cleaning process will be collected in suitable containers and disposed of as HW. 4. The HWSA will be inspected by the base environmental office, bioenvironmental office, safety office, fire department, and the Defence Infrastructure Organisation (DIO) to assess the site for any hazards or environmental, occupational health, or safety risks. The results of this inspection will be documented and kept in the HW program’s records.
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5. The site of the HWSA will be considered for inclusion in the USAFE Contaminated Lands program. This program will carry out any necessary studies, including any sampling required, to assess the site for potential contamination and restoration. 6. After the HWSA has been deemed free of any hazards or environmental, occupational health, or safety risks, all signs and references that the facility was once designated as a HWSA will be removed. Building 1218 will then be eligible for inclusion with the rest of the base facilities in the plan for closure of the installation.
All HW records (HWPS, HW inventory and disposal logs, inspection logs, HW manifests, waste analysis/characterization, training records, etc.) pertaining to the hazardous waste program at RAF Lakenheath, both the HWSA and HWAPs, will be retained by 48 CES/CEIE for a period of 3 years or archived after the closure of the facility.
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Appendix D – RAF Lakenheath and RAF Feltwell HWAP Facility Listing HWAP# Office Symbol Shop Title Building# 1 MXMFA Sheet Metal 1212 2 MXMFM Metals Technology 1212 3 MXWRS Armament Flight 1395 7 MXMD PMEL 215 8 OSLB Blue Aircrew Flight Equipment 1319 9 MXMCG Egress 1253 11 MXMCF Fuel System Repair 1220 12 OSLR Red Aircrew Flight Equipment 1319 14 MXWPC Precision Guided Munitions 1599 15 MXWPD Equipment (Trailer) Maintenance 1332 16 OSLG Gold Aircrew Flight Equipment 1370 17 MXWPA Conventional Maintenance 1466 20 SGSLM Medical Equipment Repair Center 916 21 MXMFA Corrosion Control 1219 23 MXMGS AGE 1226 24 MXMFN NDI Laboratory 1233 25 OSLM Aircrew Survival Equipment 1217 26 MXMCV Electro-Environmental 1234 27 MXMPG Secondary Power 1335 28 MXMVI Avionics (AIS) 1075 29 MXMPS Propulsion 1225 31 MXAAF Aircraft Support, 492 AMU-Blue 1319 32 MXMMX Phase Support 1212 33 MXABF Aircraft Support, 493 AMU-Gold 1370 35 MXACF Aircraft Support, 494 AMU-Red 1319 41 LGRV Vehicle Maintenance 1010 42 LGRV Paint Booth 1010 43 LGRV Battery Shop 1010 44 LGRV Allied Trades 1006 45 LGRFM Refueling Maintenance 1324 48 CEOPP Power Production 1397 50 CEOFE Electric Shop 1107 53 SGSAH Histopathology 923 55 FSCW Auto Hobby 1108 56 LMTO RAFF Deep Space Tracking 210 73 SCOT Ground Radio Maintenance 1090 77 S4C Combat Arms (RAFF) 230 109 MXMCP Hydraulics 1389 110 MXMCP Hydraulics (outside) 1389 113 FSCG Golf Course Maintenance 1289 114 S4CA Security Forces Armory 1094 131 SGD Dental Clinic 944 133 FSCW Tire and Lube 1030 136 LGRVM Fire Truck Maintenance 1200 137 OSLC Chem Def 1244 138 CEOHS Structures 1127 HWSA-01 CEIE Hazardous Waste Yard 1218
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Appendix E – Sample Forms and Templates
E1. HWAP Inspection Checklist E2. HWSA Weekly Inspection Checklist E3. Hazardous Waste Stream Review Request E4. Sample Chain of Custody
NOTE: Editable Microsoft Word/Excel versions of Appendix E – Sample Forms and Templates can be found on the RAF Lakenheath environmental eDASH website at the link below: https://cs2.eis.af.mil/sites/10626/Lakenheath/WPP/ProgramPage/Hazard ous%20Waste.aspx
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E1. HWAP INSPECTION CHECKLIST
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Site #______Shop Name ______
Date of Inspection______Inspector______
HazWaste Containers, FGS-UK 6.3.4 Yes No Comments Are the containers in good condition (no rust, dents, etc.)? Are all containers appropriate for the waste? Are incompatible wastes separated? Are all containers closed except when adding waste? Is each waste stream under the 55-gallon limit? Are different waste streams incorrectly commingled in the same container? Is there sufficient secondary containment? Are there any signs of leaks or spills? Are containers grounded for flammable liquid transfers?
Labeling, FGS-UK 6.3.4.1.4 Yes No Comments Do all containers have legible hazardous waste label? Are all required hazard diamonds present?
Hazardous Waste Accumulation Point Operating Procedures 48FW HWMP Yes No Comments Is HWAP under control of unit managing it? Locked? Is there appropriate signage w/ primary/alt POCs, phone #?
Emergency Equipment Yes No Comments Is the accessible use of communications/alarm in case of emergency?(FGS-UK C6.3.9.3.4.1) Is all personal protective equipment, as required, nearby? Is an adequate spill kit in place?
Training & Site Specific Spill Plan Yes No Comments Training - Are all site users trained annually? (FGS-UK C6.3.9.2) Training - Is training documentation maintained for 3 years? (FGS-UK 6.3.9) Has it been turned in to CES/CEIE? (48 FW HWMP) Training – Is there a Primary and Alternate appointed on program? (AFMAN32-7002 5.6.3.1.2) Site Specific Spill Plan – Is plan accurate, up-to-date, and does it include necessary map? (48FW HWMP)
E2. HWSA WEEKLY INSPECTION CHECKLIST
HWSA/Site #: ______Inspector Name: ______Inspection Date: ______Time: ______
If you answer "No" to any question in the checklist, please state what remedial actions are being taken in the bottom "Summary of Necessary Repairs/Remedial Actions" section.
# Inspection Item Yes No N/A Training Initial Training -- Have all HWSA personnel completed initial HW training prior to working with HW? (FGS- 1 UK C6.3.9.1) Refresher Training -- Have all HWSA personnel completed annual refresher HW training? (FGS-UK 2 C6.3.9.2) Location Is there an in-tact barrier or fence completely surrounding the HWSA that controls entry at all times? (FGS- 3 UK C6.3.3.4.2.2) Is the area separated from ignition sources such as open flames, cutting and welding, hot surfaces, frictional 4 heat, sparks, spontaneous ignition, and radiant heat? (FGS-UK C6.3.3.10.2)
Signage Is there a sign that reads "Danger Unauthorized Personnel Keep Out" at each entry to the HWSA? (FGS-UK 5 C6.3.3.4.3 for 5-1 thru 5-3) 5.1 Is the sign both in English and the predominant language for the host nation area? 5.2 Can the sign be seen from any approach to the HWSA? 5.3 Is the sign legible from at least 7.62 m (25 ft)? Are "No Smoking" signs, or the appropriate icon conspicuously placed where there are ignitable or reactive 6 wastes? (FGS-UK C6.3.3.10.2)
Safety 7 Is the fire alarm system in working condition? (OEBGD C6.3.3.7.1) Is an instrinsically safe telephone or a hand-held two-way radio that can summon emergency assistance 8 immediately available and in working condition? (mobile phones do not satisfy this requirement ) (FGS-UK C6.3.3.7.2) Are there portable fire extinguishers available and are they appropriate to the HW in storage (e.g. foam, inert 8 gas, or dry chemical)? (FGS-UK C6.3.3.7.3) Are the extinguishers appropriate to the HW in storage (e.g. foam, inert gas, or dry chemical)? (FGS-UK 8.1 C6.3.3.7.3)
9 Is there an eyewash and shower station in proper working order? (FGS-UK C6.3.3.7.5) 10 Is there appropriate PPE for the waste being stored? (FGS-UK C6.3.3.7.5) 11 Are all exits free from containers or any other blockages? (FGS-UK C6.3.3.5) Is there adequate aisle space for unobstructed movement of emergency fire protection equipment, spill control 12 equipment, and access to decontamination equipment in the facility if needed? (FGS-UK C6.3.3.5) 13 Is spill control equipment available? (FGS-UK C6.3.3.7.3) Container Management 14 Has each container of HW been in the area for less that 1 year? (FGS-UK C6.3.3.2) 15 Are incompatibles (i.e. flammables and reactives/oxidizers) properly segregated? (FGS-UK C6.3.3.10.2)
# Inspection Item Yes No N/A 16 Are all HW containers free from severe rusting, bulging, or structural defects? (FGS-UK C6.3.4.1.1) Are the HW containers, including overpack containers, compatible with the waste they are storing? (FGS-UK 17 C6.3.4.1.2) 18 Are all HW containers closed when not adding or removing waste? (FGS-UK C6.3.4.1.3.1) Is waste being placed in clean containers that are free from residue from previous incompatible wastes or 19 materials? (FGS-UK C6.3.4.4.2) Is grounding equipment available for containers that have flammable liquids transferred from one to another? 20 (FGS-UK C6.3.4.1.3.3) Are all HW containers marked with a HW marking and a hazard class label matching its contents (e.g. 21 flammable, corrosive, etc.)? (FGS-UK C6.3.4.1.4) Are containers holding hazardous waste opened, handled, and stored in a manner that prevents them from 22 rupturing or leaking? (FGS-UK C6.3.4.1.3.2) Secondary Containment If the storage area has free liquids: Is the secondary containment impervious to leaks, spills, and 23 accumulated precipitation until they can be removed? (FGS-UK C6.3.4.2.1) If the storage area does not have free liquids: Is the area sloped or otherwise designed and operated to drain 24 and remove liquid resulting from precipitation, or the containers are elevated or are otherwise protected from contact with accumulated liquid? (FGS-UK C6.3.4.2.3) Does the secondary containment system have sufficient capacity to contain 25% of the volume of stored 25 containers or 110% of the volume of the largest container, whichever is greater? (FGS-UK C6.3.4.2.2) Is rainwater captured in secondary containment areas being inspected/tested for contamination prior to 26 release? (FGS-UK C6.3.4.2.5) 27 Is contaminated water being treated as HW until determined otherwise? (FGS-UK C6.3.4.2.5) If leaks are present, has secondary containment been emptied of accumulated releases or retained storm water? 28 (FGS-UK C6.3.4.2.1) Recordkeeping 29 Is a written log recording all HW handled being maintained at the HWSA ? (FGS-UK C6.3.5.2) 30 Are the HW logs being maintained until the closure of the installation? (FGS-UK C6.3.5.3)
31 Are weekly HWSA inspection records being maintained for at least 3 years? (FGS-UK C6.3.5.4) Is a current copy of the RAF Lakenheath Spill Prevention and Response Plan maintained at the HWSA? (FGS- 32 UK C6.3.6.2) Are Updated training records on HWSA personnel assigned duties involving actual or potential exposure to 33 HW being kept by the HWSA manager or the responsible installation office, and retained for at least three years after termination of duty of these personnel. (FGS-UK C6.3.9.4) Summary of Necessary Repairs/Remedial Actions: Inspection Item # :
Inspection Item # :
I certify that the information in the checklist and summary above is true and accurate to the best of my knowledge. Signature
E3. HAZARDOUS WASTE STREAM REVIEW REQUEST
48 FW Hazardous Waste Management Plan
Hazardous Waste Stream Review Request Date of Request:
Requester/Generator Information
HWAP #: Organization:
Shop POC: Phone Number:
Waste Stream Information: Current HWPS # (if available):
Detailed Waste Description:
Physical Properties of Waste:
Detailed Process Description/Process Change:
Chemicals Used (include MSN and Cage Numbers, if available)
Estimated Amount Generated:
Frequency of Waste Stream Generation (circle one): non-recurring weekly monthly yearly other
Signature (Requester):
Signature/Date (48 CES/CEIE) :
Please turn in to 48 CES/CEIE Hazardous Waste Program Manager
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E4. SAMPLE CHAIN OF CUSTODY
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CHAIN-OF-CUSTODY AND LAB REQUEST WORK FORM Project Number: Client/Project Name: Project & Collection Location:
Field Sample No./ Date and Grab or Sample Sample Preservative Analysis Requested Lab Remarks Identification Time Composite Container Type
Samples: (Signature) Relinquished By: (Signature) Date: Time: Received By: (Signature) Date: Intact: Time: P.O.C.: Relinquished By: (Signature) Date: Time: Received By: (Signature) Date: Intact: (Signature) Time: Relinquished By: (Signature) Date: Time: Received By: (Signature) Date: Intact: Time: Sampler Remarks Container Seal Data Results To: Received By: (Signature) Date: Lab No.: No.: Time:
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