HAZARDOUS WASTE
MANAGEMENT PLAN
Naval Station Rota, Spain
May 2016 (Reviewed by NAVSTA HWPM)
APPROVALS
This Hazardous Waste Management Plan addresses management requirements specific to current regulated waste generation and disposal activities at Naval Station Rota, Spain.
Approved By:
CAPT, M. D. MACNICHOLL USN Date Commanding Officer NAVSTA Rota, Spain
______Date Amos Webb Installation Environmental Program Director NAVSTA Rota, Spain
______
Maria del Carmen Dominguez Date Hazardous Waste Program Manager NAVSTA Rota, Spain
Hazardous Waste Management Plan Naval Station Rota, Spain
HAZARDOUS WASTE MANAGEMENT PLAN
RECORD OF REVISIONS
The following table is provided for tracking revisions to this plan. This document shall be updated, revised, and reissued at least every five years. Additionally, the plan shall be reviewed at least annually by the Naval Station Rota Hazardous Waste Program Manager (HWPM). This plan shall be updated as necessary to reflect changes in hazardous waste management. If a change in management practices, regulatory requirements, or site conditions result in the need for a revision between scheduled annual reviews, the revision to the management plan will be made within 90 days of the change occurring. Relevant information regarding changes shall be communicated to all affected users of the HWMP. Instructions to these entities regarding implementation of the changes shall be provided by the HWPM. Each review and/or revision shall be documented in the table below. If no revisions are made as a result of the review, the review will be documented and “none” shall be entered into the “description of changes” column.
Hazardous Waste Management Plan Naval Station Rota, Spain
Date Review Name/Title Signature Description of Change(s)
Hazardous Waste Management Plan Naval Station Rota, Spain
TABLE OF CONTENTS
TABLE OF CONTENTS 2
LIST OF TABLES 2
TABLE 1-1: HAZARDOUS WASTE REGULATORY CROSS-REFERENCE
TABLE 5-1: RECORDS RETENTION MATRIX
TABLE 6-1: TRAINING REQUIREMENTS
LIST OF APPENDICES 2
APPENDIX A – STANDARD OPERATING PROCEDURES
APPENDIX B – HWAP LOCATIONS
APPENDIX C – WASTE ANALYSIS PLAN
ACRONYMS AND ABBREVIATIONS 3
GLOSSARY 6
1 INTRODUCTION 7
2 RESPONSIBILITIES 9
2.1 SPANISH BASE COMMANDER (SBC) 9 2.2 NAVSTA ROTA COMMANDING OFFICER 9 2.3 INSTALLATION ENVIRONMENTAL PROGRAMS DIRECTOR (IEPD) 9 2.4 NAVSTA Rota Hazardous Waste Program Manager 9 2.5 Defense Logistics Agency Disposition Services 9 2.6 ACTIVITY ENVIRONMENTAL COORDINATORS 10 2.7 NAVFAC FACILITIES ENGINEERING AND ACQUISITION DIVISION 10 3 HAZARDOUS WASTE ACCUMULATION AND STORAGE 10 3.1 Hazardous Waste Accumulation Points 11 3.2 Hazardous Waste Storage Area 11
4 HAZARDOUS WASTE MANAGEMENT PROCEDURES 11 4.1 Hazardous Waste Identification 11 4.2 General Container Management and Handling 12
4.2.1 WASTE SEGREGATION 12 4.2.2 CONTAINER TYPES 12 4.2.3 LABELING 12 4.2.4 SPILL PREVENTION 12 4.2.5 SECONDARY CONTAINMENT 12 4.2.6 OVERFILLING 13 4.2.7 IGNITABLE OR REACTIVE WASTES 13 4.2.8 TRANSPORTATION 13 4.3 Hazardous Waste Accumulation Points 13 4.3.1 HAZARDOUS WASTE ACCUMULATION POINT INSPECTIONS 13 4.3.2 CONTINUITY BINDER 13 4.3.3 TURN-IN OF HAZARDOUS WASTE 14 4.4 Hazardous Waste Storage Area Procedures 14 4.4.1 EQUIPMENT 14 4.4.2 SEGREGATION 15 4.4.3 INSPECTIONS 15 Hazardous Naval Station Rota, Spain 2 4.4.4 SECURITY 15 4.4.5 DISPOSAL PROCEDURES 16 4.5 Turn-in of Excess Hazardous Materials from Transient Ships 16 4.6 Turn-in of Excess Hazardous Materials from Homeported Ships 16
5 REPORTING AND RECORDKEEPING 16 5.1 Spanish Waste Manifest 16 5.2 Annual Reports 18
5.3 Records Retention 18
6 TRAINING 19 7 CONTINGENCY PLAN 20 7.1 Spill Prevention and Response Plan 20 7.2 Pollution Prevention and Waste Minimization 20
8 CLOSURE PLAN 22 8.1 Estimated Hazardous Waste Storage Capacity 22 8.2 Hazardous Waste Removal/General Decontamination 22 8.2.1 DECONTAMINATION OF NON-POROUS SURFACES 23 8.2.2 DECONTAMINATION OF POROUS SURFACES 23 8.2.3 REMOVAL OF GROUND MEDIA 23 8.3 Possible Contaminants of Concern 23 8.4 Expected Closure Date 24
9 REFERENCES 25
Hazardous Waste Management Plan Naval Station Rota, Spain 3 ACRONYMS AND ABBREVIATIONS
ADR European Agreement Concerning the International Carriage of Dangerous Goods by Road ASTM American Society for Testing and Materials AUL Authorized User List CFR United States Code of Federal Regulations CHRIMP Consolidated Hazardous Material Reutilization and Inventory Management Program CLIN Contract Line Item Numbers CNREURAFSWA Commander Navy Region, Europe Africa and Southwest Asia COLIWASA Composite Liquid Waste Sampler COR Contracting Officer Representative CTF-63 Commander Task Force Naples, IT DD-1348-1A Defense Department property transfer form DLA DS Defense Logistics Agency Disposition Services DO Delivery Order DoD Department of Defense DoDI Department of Defense Instruction DODAAC Department of Defense Activity Address Code DoN Department of Navy DOT United States Department of Transportation DTID Disposal Turn-In Document EC Environmental Coordinator EMS Environmental Management System EPA United States Environmental Protection Agency EU European Union EWC European Waste Catalogue FGS Final Governing Standards FIC Facility Incident Commander FP Flash Point HAZCOM Hazard Communication HM Hazardous Materials HAZWOPER Hazardous Waste Operation and Emergency Response HMIS Hazardous Material Information System HSIRM Hazardous Substance Incident Response Management HWAP Hazardous Waste Accumulation Point HW Hazardous Waste HWMP Hazardous Waste Management Plan HWPM Hazardous Waste Program Manager HWPS Hazardous Waste Profile Sheet HWSA Hazardous Waste Storage Area L Liter mL Milliliter NAVFAC Naval Facilities Engineering Command NAVSTA Naval Station NAVSUP Naval Supply Systems Command NFPA United States National Fire Protection Association NOSC Navy On-Scene Coordinator NSN National Stock Number OPNAV Office of the Chief of Naval Operations OPNAVINST Office of the Chief of Naval Operations Instruction P2 Pollution Prevention HazardousP2ADS Waste PollutionManagement Prevention Plan Annual Data Summary Naval Station Rota, Spain 4 PCB Polychlorinated Biphenyls POC Point of Contact POL Petroleum, Oil, and Lubricants
PPE Personal Protective Equipment PWD Public Works Department QA Quality Assurance QC Quality Control RCRA Resource Conservation and Recovery Act SDS Safety Data Sheet SOP Standard Operating Procedures SPRP Spill Prevention and Response Plan TCLP Toxicity Characteristic Leaching Procedure US United States UIC Unit Identification Code WAP Waste Analysis Plan
Hazardous Waste Management Plan Naval Station Rota, Spain 5 GLOSSARY
In addition to the definitions provided in Chapter 6 (Hazardous Waste) of the Environmental Final Governing Standards for Spain, the following terms are included in this Hazardous Waste Management Plan. Excess hazardous material – Hazardous materials used on a ship that are to be offloaded for determination as reusable hazardous material or disposal as hazardous waste. Generating activity – organization that is creating the hazardous waste. Numero de identificación fiscal (NIF) – An identifier used in many countries, including the countries of the European Union for Value Added Tax purposes.
Hazardous Waste Management Plan Naval Station Rota, Spain 6
1 INTRODUCTION
Activities at Naval Station (NAVSTA) Rota, Spain generate hazardous waste (HW) and excess hazardous materials (HM) during routine operations, such as maintenance and repair activities. The proper management and disposal of the HW is necessary to protect the health and safety of personnel aboard NAVSTA Rota and the local environment. This Hazardous Waste Management Plan (HWMP) has been developed to provide guidance related to the management of hazardous waste (HW) handling, storage, and disposal activities at NAVSTA Rota, Spain. The Hazardous Waste Program Manager (HWPM) is responsible for development, maintenance, and oversight of the implementation of this HWMP. The HWMP is specifically designed to be a working tool and to address the responsibilities and actions required of affected personnel in order to comply with requirements for the management of HW at NAVSTA Rota. These requirements are established by the Environmental Final Governing Standards for Spain (FGS-Spain), and by policies, instructions, and other applicable directives issued by Department of Defense (DoD); Department of Navy (DoN); Commander Navy Region Europe, Africa, and Southwest Asia (CNREURAFSWA); and NAVSTA Rota. Throughout this HWMP, all subsequent citations from the FGS-Spain are simply referred to as the “FGS.” In addition, it should be noted that the nomenclature for FGS section numbers includes a reference to the FGS chapter and paragraph (for example, FGS Section C6.3.1 refers to FGS Chapter 6, Paragraph 3.1). Table 1-1 provides a cross-reference between the current (2014) FGS-Spain requirements and the location of the corresponding information in this plan. The HWMP will be kept current to reflect changes in regulatory requirements and waste management activities conducted at NAVSTA Rota. The plan will be reviewed at least annually and revised as necessary (at least every five years) by the NAVSTA Rota HWPM in accordance with the instructions to the “Hazardous Waste Management Plan Record of Revisions” located at the front of this plan.
Hazardous Waste Management Plan Naval Station Rota, Spain 7 Table 1-1: Hazardous Waste Regulatory Cross-reference
Applicable FGS-Spain (May 2014) Requirement Description HWMP Section(s)
C6.3.2. Hazardous Waste Accumulation Point (HWAP) 3.1
C6.3.3. Hazardous Waste Storage Area (HWSA) 3.2
C6.3.4. Use and Management of Containers 4.2
C6.3.5. Recordkeeping Requirements 5
C6.3.6 Contingency Plan 7
C6.3.7. Tank Systems N/A
C.6.3.9. Hazardous Waste Training 6
C6.3.10. Hazardous Waste Disposal 4.4.5.
Waste Management Plan
Hazardous Waste Management Plan Naval Station Rota, Spain 8 2 RESPONSIBILITIES
Responsibilities for implementing this plan are distributed throughout NAVSTA Rota. Tasked organizations, contractors and individuals must work together to ensure effective management of the HW program. The primary program responsibilities for organizations and personnel tasked with HW management roles are described in the following paragraphs. Other secondary responsibilities are included throughout this plan.
2.1 SPANISH BASE COMMANDER (SBC)
• Contacts the Environmental Executive Agent (EEA) via the Component Chain of Command
• Serves as liaison between the EEA, NAVFAC PW Environmental Division, and the local authorities.
2.2 NAVSTA ROTA COMMANDING OFFICER
• Ensures that the responsibilities for the management of HW are carried out. • Signs the HWMP to require implementation of its requirements throughout NAVSTA Rota
2.3 INSTALLATION ENVIRONMENTAL PROGRAMS DIRECTOR (IEDP)
• Oversees the administration and general maintenance of the Installation’s Hazardous Waste Storage Area (HWSA)
2.4 NAVSTA ROTA HAZARDOUS WASTE PROGRAM MANAGER
• Assumes overall management of the HW program and reports status to the installation environmental program director (IEPD) • Provides guidance to all NAVSTA Rota personnel to ensure proper management of HW through the implementation of the HWMP and other requirements • Provides technical information and assistance to HW-generating activities at NAVSTA Rota • Ensures that the HW management program requirements are integrated into the NAVSTA Rota environmental management system (EMS) and monitored appropriately • Review and approve the HWMP • Assist generating activities in establishing HW accumulation points (HWAPs) • Conduct the annual compliance assessment of the HW management program to meet EMS requirements • Coordinates HW training and maintain records as required by FGS • Completes and submits all reports on HW management to Navy and host nation agencies (via the Spanish Base Commander) as required • Maintain copies hazardous waste management operations such as Training Certificates, ETIDs, HWPSs, and administrative records as required by the FGS • Coordinates with DLA COR any changes in the HW disposal process 2.5 DEFENSE LOGISTICS AGENCY DISPOSITION SERVICES
• Serves as the hazardous waste disposal agency for DoD. DLADS provides contract services for regulated waste disposal. • DLA HW COR reviews/approves HW disposal ETIDs for NAVSTA EV Coordinators.
Hazardous Waste Management Plan Naval Station Rota, Spain 9 • DLA Onsite HW Contractor weighs HW consignment and verifies turn in documents and send copies to DLA HW COR to generate Task Orders and process for HW documentation through DLA for removal • Oversees HW Contractor and will ensures that all pertinent hazardous waste information is correctly tracked by the DLA HW Contractor, as well as all rejection notice.
2.6 ACTIVITY ENVIRONMENTAL COORDINATORS
Serve as the environmental POCs for departments, tenant commands, and contractors operating aboard NAVSTA Rota. EVCs are the first line of communication with the NAVSTA Rota Environmental Department and assume basic environmental responsibilities within their units NAVSTA Department/Tenant Commands generating hazardous waste must designate in writing personnel to serve as the EV Coordinator and an alternate to assume responsibilities for the proper accumulation, storage, and disposal of the HW. Designated EVCs will assume overall responsibilities for management of HW of each HWAP within their Department, while generators of HW must be capable of recognizing, tracking, and maintaining all necessary documentation and processes for proper HW management. Main duties of the EVCs include, but are not limited to, the following tasks: Collecting, containerizing, labelling, and marking containers of HW in accordance with this plan Ensuring all personnel who handle HW or who are otherwise involved in the HW management within their Department are identified and receive required training. Managing Department HWAP(s) in accordance with FGS requirements. Performing and documenting weekly inspections of the HWAP(s) with follow up on all corrective actions. Allow facilities, shops, and equipment to be inspected (e.g., Safety inspectors, NAVFAC EV inspectors, Regional Environmental Agency) Preparing all necessary disposal documents and transporting HW from the HWAP to the HWSA. Ensuring maintenance and retention of HW documents, according to Spanish FGS (e.g., Weekly inspections, ETID-DD Form 1348-1A, HWPS, Training records, etc) Creating and maintaining a Department HW Continuity Binder as described in section 4.3.2 of this HWMP
2.7 NAVFAC FACILITIES ENGINEERING AND ACQUISITION DIVISION Ensures that contracts for all work to be accomplished at NAVSTA Rota include the condition that Contractors shall conform to all requirements of the FGS, Spanish and local requirements, OPNAV environmental instructions and this HWMP.
NAVFAC Engineering and Acquisition Director ensures EV Deficiencies from Contractors will be send to NAVFAC EV Director as well as corrections within 30 days of notifications.
Hazardous Waste Management Plan Naval Station Rota, Spain 10 3 HAZARDOUS WASTE ACCUMULATION AND STORAGE
HWAPs and HWSA are managed in accordance with Spanish FGS, Chapter 6.
3.1 HAZARDOUS WASTE ACCUMULATION POINTS A HWAP at NAVSTA Rota is a shop, site, or other work center where hazardous wastes are accumulated until removed to the Hazardous Waste Storage Are (HWSA) or shipped for treatment or disposal. A HWAP may be used to accumulate <210 liters (55 gallons) of hazardous waste, or 1 liter (1 quart) of acute hazardous waste, from each waste stream. The HWAP must be at or near the point of generation and under the control of the Department EV Coordinator. The HWAP must be designated and operated to provide appropriate segregation for the different waste streams, including those that are chemically incompatible. Each HWAP will have warning signs (National Fire Protection Association – NFPA) or appropriate warning signs appropriate for the waste being accumulated. The HWAP will meet all standards of the Spanish FGS, Chapter 6. When these limits have been reached or when an individual storage container is full, EVC must prepare necessary disposal ETID documents and transfer full container(s) to the HWSA within five days. All HW Generated at the HWAP must meet all FGS Chapter 6, standards. Naval Station Rota does not transport HW off-site for disposal directly from the HWAPs.
3.2 HAZARDOUS WASTE STORAGE AREA The HWSA at NAVSTA Rota is used to deposit and process all of the containers of HW generated at HWAPs base-wide, and is operated by the Defense Logistics Agency Disposition Services (DLA-DS) HW contractor. The HWSA is a fenced area with a building that provides for segregated storage, a shelter to provide cover for the HW container processing area, shelving for storage of containers, and a modular unit that serves as an office for the DLA- DS HW contractor. The HWSA is located at Building 1811 at NAVSTA Rota and has been specifically located in such a way as to meet the location and design requirements of FGS- Spain. Per FGS requirements, hazardous wastes will not be stored in the HWSA for longer than six months. If necessary, installation will request an extension by providing sufficient information to the SBC for approval to store waste greater than six months. The HWSA is open to accept and process HW from 07:30 – 16:30 Monday through Friday. Generating activity EVCs are aware of these operating hours and make arrangements to deliver HW only during those hours.
4 HAZARDOUS WASTE MANAGEMENT PROCEDURES
4.1 HAZARDOUS WASTE IDENTIFICATION Generally, if a waste presents potential harm to people or the environment, it will be treated as a HW. Hazardous waste can be identified by a hazardous characteristic (flammability, corrosivity, reactivity, or toxicity) or by being specifically listed in FGS- Spain, Addendum 2, European Waste Codes. With support and guidance from the HWPM, the EC at generating activities identify the materials and processes which create wastes and determine which of these wastes must be managed and disposed as HW. A HW profile sheet is completed by the EVC for each waste stream generated by the activity and Hazardous Waste Management Plan Naval Station Rota, Spain 11 submitted via DLA AMPS/ETID Website. DLA HW COR reviews and accepts before that waste is accumulated and transported to the HWSA. The profile will be kept in the Department EV Continuity Binder by the EVC. Master copy of the HWPSs will be maintained by the DLA HW COR. If the process or materials involved in generating the waste change, a new HW profile is submitted to document the new waste stream by generated Department EVC. The waste analysis plan (WAP) is included as Appendix C.
4.2 GENERAL CONTAINER MANAGEMENT AND HANDLING The ECs assigned in each area are responsible for the management of HW in that activity. Hazardous waste must be accumulated only in HWAPs.
4.2.1 WASTE SEGREGATION Waste stream integrity is maintained in the HWAPs. Each generating activity must be able to account for exactly what wastes go into each container, and segregation of these wastes and of HW from other wastes must be maintained. This is typically accomplished by secured containers with controlled access. Waste segregation is also important from a safety perspective. Mixing of incompatible wastes may cause a fire, explosion, or release of toxic vapors. To protect against such occurrences, each waste stream is accumulated in separate containers compatible with the hazardous waste and the containers are physically separated to prevent commingling of the HW.
4.2.2 CONTAINER TYPES As necessary, generating activities will purchase and use appropriate DOT/ADR-certified drums and UN cardboard boxes to accumulate HW. These containers are obtained from the DLA Distribution Services HW contractor or from other sources and are paid for by the using activity. Department EVCs will be considering compatibility of materials with appropriate disposal container, rate of generation and cost for disposal. For example, if only 25 gallons of a material are generated in six months, it is more effective to select a 30 gallon container than a 55 gallon container. Similarly, if the activity is generating liquid waste, a closed-top container should be selected.
Hazardous waste is turned in to the HWSA in these containers and are not repackaged for disposal unless there are container deficiencies identified. Containers at the HWAPs and in the HWSA are kept in good condition, free from severe rusting, bulging, or structural defects. All containers used for the accumulation of waste are compatible with the HW being deposited. 4.2.3 LABELING Hazardous waste drums must have a bilingual label to identify:
• European waste code • HW Generator Name, UIC, and contact information of generating activity • Technical name of the HW • Start and end dates of accumulation • Hazard class of the HW contained • ETID number
4.2.4 SPILL PREVENTION Hazardous waste containers are closed during accumulation and storage, except when it is necessary to add or remove waste. Containers are stored in HWAPs in such a way as to prevent rupture and minimize the likelihood of being tipped over or otherwise damaged. Containers holding flammable liquids must be grounded. The EVC at generating activities monitor the containers daily and each generating activity retains appropriate spill cleanup
Hazardous Waste Management Plan Naval Station Rota, Spain 12 materials on-site for use in the event of a spill. Spent spill cleanup materials are containerized and disposed as HW.
4.2.5 SECONDARY CONTAINMENT Hazardous waste containers of free liquids are placed in secondary containment that is impervious and able to contain leaks, spills, and precipitation. The containment will be sized to contain either 10% of the total volume of stored containers or the total volume of the largest single container, whichever is greater. Containment may include spill pallets, storage lockers with containment, imperviously bermed areas, or other such control structures. Hazardous waste containers that do not contain free liquids are not required to be on secondary containment, but are required to be placed in HWAPs that allow for protection from exposure to the elements.
4.2.6 OVERFILLING HW containers are not filled over 90% of their capacity to allow adequate head space for the potential expansion of liquids and HW vapors.
4.2.7 IGNITABLE OR REACTIVE WASTES All HWAPs are located a minimum of 15 meters from the property boundary. In addition, HWs that are ignitable or otherwise reactive are protected from sources of ignition or reaction, including but not limited to: open flames, smoking, sparks, and spontaneous ignition. Water-reactive wastes and oxidizers are separated from flammable and combustible liquids, and containers of flammable liquids are grounded.
4.2.8 TRANSPORTATION In accordance with the procedures in appendix A, containers of HW are transported using equipment designed for the task, and containers are secured to pallets before moving the pallet. The EVC for each generating activity is responsible for safely transporting the containers from the HWAP to the HWSA. When transporting HW only government owned vehicles (GOVs) will be used. No personnel at NAVSTA Rota are authorized to transport HW outside of the installation boundary or along public roadways.
4.3 HAZARDOUS WASTE ACCUMULATION POINTS In addition to the requirements of sections 4.1 and 4.2, personnel will adhere to the following procedures for the management of HWAPs. A list of HWAPs is provided in Appendix A.
Each HWAP is specifically designated at or near the point of generation and provided with appropriate NPFA or International signage. No more than 208 liters (55 gallons) per waste stream may be accumulated at the HWAP.
4.3.1 HAZARDOUS WASTE ACCUMULATION POINT INSPECTIONS HWAPs are inspected weekly by Department EVCs for leaks and deterioration of containers. Secondary containment systems are inspected for defects and accumulating liquids. Inspections are documented using form provided by NAVFAC Environmental Office.
4.3.2 CONTINUITY BINDER Each generating activity EVC maintains an Environmental Continuity Binder to document HW management activities. At a minimum, the binder contains:
• Contact information for pertinent personnel associated with EV Program management Hazardous Waste Management Plan Naval Station Rota, Spain 13 • Training records for three years after termination of duty of personnel • HW weekly inspections for three years • HW profile sheets for three years • Completed HW turn-in documents for five years • Extra Department EV information need it Maintaining Department EV continuity binder is the responsibility of the EVC, and is turned over with personnel changes. If the HWAP closes, the binder is submitted to the HWPM for archiving.
4.3.3 TURN-IN OF HAZARDOUS WASTE A HW profile sheet is completed by the EVC for each waste stream generated by the activity and submitted via DLA AMPS/ETID Website for DLA HW COR to review and acceptance before that waste is accumulated/transported from the HWAP to the HWSA. The profile will be kept at the DLA AMPS/ETID Website, also in the continuity binder by the EVC. Once the HW container at the HWAP is 90% full, the container is sealed and prepared for delivery to the HWSA within five working days after receiving approved ETID for timely disposal. The EVC works with the DLA Disposition Services HW Contracting Officer Representative (COR) to enter the container into the DLA Disposition Services Electronic Turn-In Document (ETID) system. The DLA Disposition Services HW COR trains each EVC on the process to access the system, register as a user and enter the required information. Once the container information is entered into ETID, the DLA Disposition Services HW COR reviews it, recommends corrections or adjustments by the EVC if necessary, and forwards to EVC ETID generator who will sign it and send it to HWPM for signature. HWPM sends signed ETIDs to generated ETID EVC and HW Contractor for final disposal process.
Once the documentation has been approved, Department EVCs will print copies of the turn-in document and profile, and transport the HW container(s) to the HWSA during operating hours. There, the DLA Disposition Services HW contractor reviews paperwork, inspects the container, logs it into the facility inventory, weight and places it in the proper storage area. If the turn-in does not meet the requirements for the container and/or the documentation, DLA HW Contractor provides the EVC with a rejection notice. The EVC must return the container to the HWAP and has 48 hours to correct the deficiency and return the container to the HWSA. DLA HW contractor and DLA Disposition Services HW COR track all rejection notices. If the HW is accepted, the EVC will receive a copy of the accepted turn-in document that is then placed in the continuity binder. The DLA Disposition Services HW COR adds the container to the delivery order directly from the ETID system.
4.4 HAZARDOUS WASTE STORAGE AREA PROCEDURES In addition to the requirements of sections 4.1 and 4.2, personnel will adhere to the following procedures for the management of HWAPs. The HWSA at NAVSTA Rota is located at Building 1811. The HWSA is designed, constructed, maintained, and operated to minimize the possibility of a fire, explosion, or any unplanned release of HW constituents to air, soil, groundwater, or surface water that could threaten human health or the environment. Any modification to the existing HWSA or construction of a new HWSA must also meet these requirements. HW should not be stored longer than 180 days (6 months) without an operating permit.
4.4.1 EQUIPMENT The HWSA is equipped with the following:
• An internal communications or alarm system capable of providing immediate emergency instruction (voice or signal) to HWSA personnel.
Hazardous Waste Management Plan Naval Station Rota, Spain 14 • A device such as an intrinsically safe telephone (immediately available at the scene of operations), or a hand-held two-way radio, for the summoning of emergency assistance from Installation security, fire departments, or emergency response teams.
• Portable fire extinguishers, fire control equipment appropriate to the material in storage, spill control equipment, and decontamination equipment.
• Water at adequate volume and pressure to supply water hose streams, foam producing equipment, automatic sprinklers, or water spray systems.
• Readily available PPE (appropriate to the materials stored), eyewash station, and shower facilities.
Testing and maintenance is performed by DLA HW Contractor for all HWSA equipment to ensure proper operation in time of emergency.
4.4.2 SEGREGATION The HWSA provides appropriate segregation for HW through its design and operation. The DLA Disposition Services HW contractor ensures that HW are compatible with their containers and are located in the properly designated locations. Ignitable, reactive, or incompatible wastes are stored to the north of the HWSA in an enclosed Building 1811 comprised of six separate walled compartments to prevent potential threat to human health or the environment. All HW liquid containers with flammables will be stored at Flammable Lockers located at HWSA Compound. 4.4.3 INSPECTIONS Minimum frequencies of monitoring HWSA by the DLA HW contractor are as follows:
• Containment storage areas must be inspected weekly for leaks and deteriorating containers and containment systems. Secondary containment systems shall be emptied of accumulated releases or storm water and inspected for defects.
• Areas subject to spills (loading and unloading areas) are inspected daily when in use.
The DLA HW Contractor inspects HWSA monthly for malfunctions, deterioration and discharges that may occur, or result in, a release of HW constituents to the environment or threat to human health. DLA HW Contractor will inform the HWMP for any problems or deteriorations at the HWSA. Inspections by the HWPM are conducted annually. Inspections include all equipment and areas involved in storage and handling of HW, including all containers and container storage areas, and all monitoring equipment, safety and emergency equipment, security devices, and operating and structural equipment (such as dikes and sump pumps) that are important to preventing, detecting, or responding to environmental threats or human health hazards. Inspection records are retained and include the date and time of inspection, name of inspector, notation of the observations made, and the date and nature of any repairs or other remedial actions. The appropriate form for conducting the inspections is provided by the HWPM in appendix A of this plan. NAVSTA Rota is responsible for remedying any deterioration or malfunction of equipment or structures that the inspection identifies on a schedule which ensures that the problem does not lead to an environmental or human health hazard. The DLA Disposition Services HW contractor tracks all inspection deficiencies until deficiencies are corrected. Inspection forms must be available for HWPM & DLA HW COR.
4.4.4 SECURITY The HWSA is secured to prevent any unknown entry, and to minimize the possibility for unauthorized entry onto the HWSA grounds. A fence in good repair completely surrounds the HWSA, combined with a locked gate to control entrance at all times. Additionally, NAVSTA Rota security performs periodic surveillance rounds in the vicinity of the HWSA
Hazardous Waste Management Plan Naval Station Rota, Spain 15 perimeter. During operating hours, the DLA Disposition Service contractor is present onsite at the HWSA. A sign is posted at the HWSA, in English and Spanish, with the words, “Danger Unauthorized Personnel Keep Out, Peligro, No permitida la entrada a personal no autorizado”. This sign is legible from a distance of at least 25 feet as required.
4.4.5 DISPOSAL PROCEDURES HW is disposed through DLA Disposition Services.
In preparation for disposal of the HW from the HWSA, the DLA Disposition Services HW COR prepares a delivery order request and submits it to the DLA Disposition Services HW disposal contractor. The HW disposal contractor prepares a Spanish waste manifest, and returns the manifest to NAVFAC PW EV office HWMP to obtain designated signatory from Military POCs. The DLA Disposition Services HW contractor and the DLA Disposition Services HW COR, are present for the HW pick-up by the HW disposal contractor. Only the designated member(s) of the military is (are) authorized to sign the manifest prior to departure. 4.5 TURN-IN OF EXCESS HAZARDOUS MATERIALS FROM TRANSIENT SHIPS When coming into port at NAVSTA Rota, transient ships may request permission to offload excess hazardous materials. This request is made to COMSERVFORSIXTHFLT (CTF63) in Naples. CTF 63 Naples will approve funds and approved documents for the offload. These documents will be provided to the requesting ship and to NAVSTA Rota NAVFAC PWD Environmental Division HWPM. Before offloading begins in-port, HWPM/NAVSUP Afloat Technician and designated ship personnel will ensure that the turn-in documents are completed and signed, SDSs for the material being offloaded is provided, and that the corresponding container is properly labeled (Bilingual HW Labels will be provide by HWPM) with the Ship’s name, document number, and the type/name of material contained. Prior to offloading, HWPM and/or NAVSUP Afloat Technician will inspect the container(s) and documentation(s), once all hazmat are approved excess hazardous material is offloaded from the ship and transported to the HWSA during normal operating hours. NAVSTA Rota does not provide transport. The designated ship personnel is responsible for arranging transportation from the pier to the HWSA.
4.6 TURN-IN OF EXCESS HAZARDOUS MATERIALS FROM HOMEPORTED SHIPS Homeported ships are required to designate an Afloat Environmental Protection Coordinator (AEPC). The AEPC functions in a manner similar to the EVCs for ashore activities. When excess hazardous material requires offload and transfer to the HWSA, the AEPC follows the same procedure as outlined in section 4.3.3 for ashore activities associated with the preparation of turn-in documents. Once the turn-in documents are approved, NAVSUP Afloat Technician is requested to come on-board to inspect the containers and documentation. Once inspected and approved for turn-in, the AEPC arranges for offload of the excess hazardous material and transfer to the HWSA. Refer to appendix A for additional information. NAVSUP Afloat Technician is requested to maintain hazmat offload documents.
Hazardous Waste Management Plan Naval Station Rota, Spain 16 5 REPORTING AND RECORDKEEPING
5.1 SPANISH WASTE MANIFEST A Spanish waste manifest (Hoja de Control y Seguimiento) is prepared by the DLA Disposition Services HW contractor for each shipment of HW for disposal. The content of the manifest is verified during the loading of the waste at the HWSA. This manifest is reviewed and approved by the DLA Disposition Services HW COR before the HW disposal contractor is allowed to remove HW. The manifest will accompany all HW from NAVSTA Rota to its final destination, in accordance with Spanish Law.
At NAVSTA Rota, the Spanish Navy Fiscal Identification Number (NIF) is used as the Waste Producer Identification Number by the Junta de Andalucía. The NIF is used for recordkeeping, reports and manifests for the management of waste. Required manifest information includes:
• Generator’s name, address, and telephone number.
• Generator’s NIF.
• Transporter’s name, address, and telephone number.
• Destination, company name, address, and telephone number.
• Description of waste (physical state and waste code).
• Total quantity of waste.
• Date of shipment.
• Date of receipt. The waste manifest process in Spain is illustrated in Figure 4-1 and the documentation and record-keeping requirement in the NAVSTA Rota are included in Table 4-1. The DLA HW Contractor is required to send final and signed Spanish Waste Manifests to DLA HW COR and HWPM.
Hazardous Waste Management Plan Naval Station Rota, Spain 17 Transporter Numbered copies 5 of manifest 6
5 1 2 6 3 Waste 4 Generator ( Retain Delivery HW Disposal Facility Certificate)
6 3 2 4
Provincial Office of Provincial Office of 4 Regional Regional Environmental Agency Regional Environmental ( Junta de Andalucía ) Environmental Agency (Destination) Agency (Generation)
Source: Order 12 of July of 2002 of Junta de Andalucía
5.2 ANNUAL REPORTS The HWPM submits annual reports to both the Junta de Andalucía and DoD. The report to the Junta de Andalucía is completed and submitted to the Spanish Base Commander for submittal to the regulatory agency. The annual report to the Navy (P2ADS) is submitted by the HWPM following the annual hazardous waste data call.
5.3 RECORDS RETENTION NAVSTA Rota retains HW records in accordance with the requirements of Table 5-1. Table 5-1: Records Retention Matrix
Record Time Retained Responsibility for Record Maintenance
Turn-in documents (e.g., Five (5) years Department EV Continuity binders, DLA DD1348-1A) Disposition Services HW COR, HWPM
Inspection Records Three (3) years from Responsible inspection parties: EVC, DLA (Equipment, Containers and date of inspection Disposition Services HW contractor, Security) HWPM
Manifests Five (5) years DLA Disposition Services HW COR, HWPM
Waste Analysis/ Three (3) years after Department Continuity Binders, DLA Characterization Records closure of the HWSA Disposition Services HW COR, HWPM
Waste profiles Three (3) years after Department Continuity Binders, DLA closure of the HWSA Disposition Services HW COR, HWPM
Hazardous Waste Management Plan Naval Station Rota, Spain 18 HW Log Five (5) years after DLA Disposition Services HW contractor last entry
Training Records Five (5) years after Department Continuity Binders, HWPM termination of duty of personnel
Junta de Andalucía Annual Five (5) years HWPM Waste Report
HW DoD P2ADS report Three (3) years HWPM
Hazardous Waste Management Plan Naval Station Rota, Spain 19 6 TRAINING
Personnel assigned to duties involving actual or potential exposure to HW or excess hazardous materials must receive appropriate training prior to assuming those duties. Personnel assigned to these duties, including the EVC for ashore activities and the AEPC for homeported ships, shall work under direct supervision until the appropriate training is completed. The training program ensures that facility personnel are able to respond effectively to emergencies, safely use equipment, and protect themselves from safety and health hazards associated with their assigned duties. Additionally, the training ensures that the assigned personnel understand accumulation and storage, inspections, transportation, and recordkeeping requirements. Training requirements are presented in Table 6-1. Table 6-1: Training Requirements
Hazardous Communication by Safety All personnel at NAVSTA Rota EMS general awareness
Introduction to the Hazcom
Overseas HW Facility Operator – EVCs/AEPCs initial and refresher HSIRM – initial and refresher
Introduction to Hazcom
Overseas HW Facility Operator – HWSA Operator initial and refresher HSIRM – initial and refresher
Other HW courses as required by contract
Overseas HW Facility Operator – HWPM initial and refresher
Hazardous Waste Management Plan Naval Station Rota, Spain 20 7 CONTINGENCY PLAN
The NAVSTA PWD Environmental Division has implemented a spill prevention and pollution control Program and maintains a Spill Prevention and Response Plan (SPRP).
7.1 SPILL PREVENTION AND RESPONSE PLAN The prevention section of the SPRP provides information on responsible parties, inventory of storage/handling sites, inventory of petroleum, oil, and lubricants (POL) and hazardous substances, arrangements for emergency services and equipment, an evacuation plan, and written procedures for the prevention and reporting of POL and hazardous substance releases. The spill control section of the SPRP provides responsibilities, procedures and responses to contain and clean up spills according to a classification scheme based on the type and amount of spilled material. A description of immediate response actions is provided along with the training requirements and procedures for Facility Response Team (FRT) alert and response. This section also includes provisions for coordination with the Facility Incident Commander (FIC), Installation commander, emergency response manager, Spanish Navy, and regional Navy On-Scene Coordinator (NOSC), as appropriate. Clean-up methods, procedures and techniques to identify, contain, disperse, reclaim and remove POL and hazardous substances are outlined, as are procedures for reuse and disposal of recovered substances. Finally, this section provides details on those tasks to be accomplished prior to resuming normal operations at the site. The reporting section of the SPRP addresses record-keeping and notification procedures. A copy of the plan is maintained at the PW Environmental Office by Spill Response Coordinator.
7.2 POLLUTION PREVENTION AND WASTE MINIMIZATION Minimizing generation of HW is an important objective of Pollution Prevention (P2) at NAVSTA Rota. P2 is a departure from years of end-of-the-pipe waste management practices and establishes a cradle-to-grave approach to waste management. The Pollution Prevention Act of 1990, the primary driver behind P2 initiatives, encourages waste generators to adopt new principals guiding waste management practices. There is a hierarchy of waste minimization practices and management options to assist in the reduction and elimination of hazardous material use and waste generation. The hierarchy includes investigating source reduction as the primary means of reducing pollution, reviewing recycling alternatives after all source reduction options have been examined, considering treatment after recycling and source reduction has been deemed unfeasible, and using disposal only as the last resort after all other options have been exhausted. Pollution Prevention and Waste Minimization is managed by NAVFAC EV Solid Waste & QRP Recycling / Pollution Prevention Manager.
Pollution prevention at NAVSTA Rota focuses on planning for and evaluating the use of materials, processes, or practices in order to reduce or eliminate wastes at the source before they become an environmental concern as waste. The goal of P2 is to establish a long-term downward trend in the volumes of wastes generated and pollutants released to the environment. By achieving this goal, the costs resulting from reactionary waste management practices and dependence on hazardous materials use would also be greatly reduced. NAVSTA Rota has implemented a P2 Plan that assists with the identification, evaluation, implementation, and tracking of P2 initiatives. Additionally, NAVSTA Rota actively works to reduce waste generation at the source. The Consolidated Hazardous Material Reutilization and Inventory Management Program Hazardous Waste Management Plan Naval Station Rota, Spain 21 (CHRIMP) contributes to the minimization of waste by reducing stored inventories of hazardous materials in the work centers. Hazardous materials are issued to base employees and the materials remaining after use are returned to CHRIMP for reuse by other departments. As a result of this reuse and sharing process, lesser quantities of hazardous materials are being ordered by multiple organizations and the potential for expired materials is reduced.
Hazardous Waste Management Plan Naval Station Rota, Spain 22 8 CLOSURE PLAN
This closure plan has been developed for the HWSA at NAVSTA Rota, Building 1811 to minimize or eliminate post-closure releases of HW, hazardous constituents, leachate, contaminated runoff, or HW decomposition products to the ground, surface water, or atmosphere. Closure refers to the de-commissioning of the HWSA and associated activities, including HW accumulation, storage, or disposal. An entire installation does not have to be shut down to initiate closure. The “active portion” refers to that part of the installation where HW accumulation, treatment, storage, or disposal operations are conducted or have been conducted. This closure plan must be performed if any of the following situations occur: • Use change of the HWSA at NAVSTA Rota, Building 1811. • Use change of any section of the HWSA at NAVSTA Rota, Building 1811. • Closure of the whole HWSA at NAVSTA Rota, Building 1811. • Partial Closure of the HWSA at NAVSTA Rota, Building 1811
Following implementation of this closure plan, the Installation Environmental Program Director will certify that the HWSA has been closed in accordance with the closure plan and applicable documentation will be forwarded to the Environmental Executive Agent for the closure file.
8.1 ESTIMATED HAZARDOUS WASTE STORAGE CAPACITY Hazardous waste storage at the HWSA is within Building 1811 and on the paved areas within its fence line. Solid HW may be stored directly on the paved areas, which liquid wastes are stored on secondary containment pallets or lockers located at compound. Hazardous waste are typically stored in single layer (i.e., not stacked on one another). The majority of HW kept in the facility is stored in 55-gallon or smaller DOT/ADR certified containers. The estimated storage capacity of the facility is 40,480 gallons, or 736, 55 gallon drums.
8.2 HAZARDOUS WASTE REMOVAL/GENERAL DECONTAMINATION All containers are sealed and labeled in Spanish and English prior to shipment. Following container removal through DLA Disposition Services, all foundations and drains will be washed down, and wash water will be contained until a sample is analyzed by a certified laboratory. If warranted, wash waters will be drummed and transported for proper disposal. Facility decontamination will be performed by trained personnel. The services of these personnel will be obtained at the time of closure notification in accordance with contractual procedures established by NAVSTA Rota PWD Environmental Division or DLA Disposition Services. Requirements for decontamination will be prescribed by contract and will require the contractor to provide all necessary equipment and protective clothing to safely complete decontamination. Hand equipment used for decontamination will either be cleaned or discarded as regulated waste. Small items can be cleaned in containers with the wash water ultimately being added to drums for disposal. Larger equipment items can be cleaned in an area where the
Hazardous Waste Management Plan Naval Station Rota, Spain 23 wash water can be accumulated in a sump or trough. Wash water will be removed from the sump or trough and placed in drums for disposal. Decontamination of the facility will be conducted under the supervision of PW Environmental Division and trained technicians. During decontamination procedures, all personnel will wear the prescribed personal protective equipment. Prior to leaving the site, all personnel will remove and discard those items that cannot be cleaned for reuse, and the materials, including cleaning fluids, will be sealed in a container and transported offsite for disposal.
8.2.1 DECONTAMINATION OF NON-POROUS SURFACES Following waste container removal, the HWSA must be decontaminated in order to obtain clean closure. Decontamination of non-porous surfaces associated with HW storage will be washed down, and wash water will be contained until a sample is analyzed by a certified laboratory. A detergent and/or steam cleaning may be used if necessary in order to remove surface contamination.
Verification sampling will be performed following decontamination. Wipe samples will be collected from all decontaminated surfaces.
8.2.2 DECONTAMINATION OF POROUS SURFACES If wipe samples indicate that HW residues remain in porous surfaces, such as concrete, after initial decontamination, removal of all or part of these surfaces may be necessary. Naval Station Rota NAVFAC PWD will determine which is more economically feasible: complete removal of the porous surfaces or removal of certain layers of the porous surfaces. The main goal will be to remove contamination in the most effective manner possible. If layers of porous surfaces are removed, wipe sampling of the remaining substrate will be conducted to verify that contaminants have been removed. Contaminated surfaces removed from the HWSA will be disposed of as HW through DLA Disposition Services.
8.2.3 REMOVAL OF GROUND MEDIA Hazardous waste is not generally stored on permeable surfaces (e.g., gravel, dirt), and the ground beneath the HWSA is paved. If NAVSTA Rota PWD Environmental Division personnel identify a potential area of contamination outside of the paved surfaces, soil samples will be collected and analyzed for possible HW constituents. Contaminated soil, if small in quantity, will be removed with hand towels or shovels and placed in ADR-certified containers. These containers will be properly sealed, labeled in Spanish and English, and disposed as HW through DLA Disposition Services. If larger quantities of soil require removal, appropriately sized mechanical equipment will be used to remove the soil and place it in a suitable covered removal container pending ultimate removal. Exact procedures will be determined by NAVFAC Environmental Division Director after sample analysis defines the extent of the contamination. Soil samples will be taken at locations where there is evidence of spills or leaks. Background samples, in areas up-gradient from the HWSA, will also be collected. Downgradient samples will be obtained to evaluate any migration of contaminants from the HWSA. Soil samples will be collected at 20-foot intervals around the HWSA at a distance of 2 feet from the fence line and at a depth of up to 6 inches. Based on the results obtained from the analysis of the samples, additional analysis at additional locations may be required to define the extent of the contamination. The entire site will be re-graded as necessary to prevent erosion subsequent to closure.
Hazardous Waste Management Plan Naval Station Rota, Spain 24
8.3 POSSIBLE CONTAMINANTS OF CONCERN Given the variety of the waste types that are stored at the HWSA, wipe, wash water, and soil samples should be analyzed for the following constituents: • Volatile organic compounds • Semi-volatile organic compounds • Toxicity (organic and inorganic)
8.4 EXPECTED CLOSURE DATE The HWSA is not currently scheduled for closure.
Hazardous Waste Management Plan Naval Station Rota, Spain 25
9 REFERENCES
Naval Station Rota Pollution Prevention Plan. U.S. Department of Defense, Final Governing Standards, Spain. U.S. Department of Defense Directive 4160.21 series, “Defense Materiel Disposition Manual.”
Chief of Naval Operations Instruction. (2014, January 10). 5090.1D, Environmental Readiness Program. OPNAV M-5090.1. Washington, DC: Department of the Navy. Department of Defense. (2013, November 1). DoDI 4715.05, Environmental Compliance at Installations Outside the United States. Department of Defense.
Hazardous Waste Management Plan Naval Station Rota, Spain 26
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Appendix A – Standard Operating Procedures
This appendix contains Standard Operating Procedures (SOPs) for management of HW at NS Rota. These SOPs are based on the instruction included in this HWMP. • HW Characterization • HW Container Management • HWAP Operations • HWSA Operations • Turn-in Procedures (Including ship turn-in procedures) • Disposal Procedures
SOP: HAZARDOUS WASTE CHARACTERIZATION
General Information
Hazardous waste characterization is the identification, description, and quantification of constituents in a hazardous waste stream. It is important that HW is accurately characterized to ensure proper control, timely disposal, and avoidance of costly HW contract modifications. Hazardous waste is categorized according to the European List of Wastes codes specifically listed in the FGS. Waste stream documentation is required to complete the Hazardous Waste Profile Sheet.
Responsibility
It is the responsibility of the generating activity to maintain the identity of the materials and processes which create waste. The generating activity’s knowledge of the raw materials used and understanding of the waste generating process is usually sufficient to characterize the waste and preclude the need for analytical services.
NAVSTA Rota Department Environmental Coordinators are responsible for ensuring that procedures are adhered to and wastes are properly characterized for disposal.
Applicability
• Unused/partially used containers of hazardous material with legible labels can be characterized using SDSs as supporting documentation.
• Waste generated as a result of an industrial process can be characterized using generator knowledge of the raw materials used and process contaminants.
• Unknown or process wastes which do not have sufficient supporting documentation to adequately characterize the waste will be subject to the requirements of the Waste Analysis Plan.
Procedures
• Environmental Coordinators shall ensure hazardous material SDSs correspond to the waste generated in their work centers. Consult DLA HW COR to determine if supporting data is sufficient to complete the HWPS or if additional action is needed.
• If not sufficient data is supported a laboratory analysis is required to characterize an unknown waste. Laboratory reports and written interpretation of the results will be the supporting documentation for waste characterization and completing the HWPS. Laboratory Analysis can be obtained by submitting an ETID for Identification of Unknown Liquid or solids for disposal classification, which is a Contract Line Item of the DLA HW Contract for NAVSTA.
SOP: HAZARDOUS WASTE CONTAINER MANAGEMENT
General Information
Hazardous waste is managed from the point of generation to disposal in ADR-certified containers as an effective means to minimize exposure when handling waste.
Responsibility
The generating activity EVCs ensure the overall management of waste in their respective HW Accumulation Points.
NAVSTA Rota PWD Environmental Division HWPM and DLA HW COR are responsible for establishing waste container management procedures that address the specific procedures below.
Contractors performing work aboard NS Rota will coordinate with NAVFAC Contracting Office, DLA HW COR and NAVFAC EV Office for specific instructions prior to accumulating hazardous waste in containers.
Applicability
• All containers of hazardous waste.
• Containers of unknown or undetermined content will be presumed hazardous waste and managed as such until supporting documentation is provided.
Procedures
• WASTE SEGREGATION o Non-HW must not be mixed with HW, and each waste should be accumulated in separate DOT/ADR containers. o Separate containers in such a manner as to allow sufficient access while maintaining physical distance from containers of other materials.
• CONTAINER TYPES o Use DOT/ADR approved containers sized appropriately to the specific waste stream. o Containers must be chemically compatible with the waste. o Ensure containers are in good condition.
• LABELING o Hazardous waste containers are marked and labeled in Spanish and English to identify: • HW Generator Name, UIC, and contact information of generating activity • Technical Name of HW • Start and end dates of accumulation • Hazard class of the HW contained • European waste code • ETID number
• SPILL PREVENTION • Hazardous waste containers must be closed during accumulation and storage, except when adding or removing waste. • Prevent rupture and minimize the likelihood of containers being tipped over or damaged.
• Ground containers holding flammable liquids. • Monitor containers daily. • Retain appropriate spill cleanup materials on-site for use in the event of a spill. • Containerize spent cleanup materials and dispose as HW.
• SECONDARY CONTAINMENT • Containers of hazardous waste free liquids are placed in secondary containment that is impervious and able to contain leaks, spills, and precipitation. • Size the containment to contain either 10% of the total volume of stored containers or the total volume of the largest single container, whichever is greater. • Containment may include spill pallets, storage lockers with containment, imperviously bermed areas, or other such control structures. • Hazardous waste containers that do not contain free liquids are not required to have sized secondary containment, but are required to be placed in HWAPs that allow for protection from exposure to the elements.
• OVERFILLING • Containers of hazardous waste are not filled over 90% of their capacity to allow adequate head space for the potential expansion of liquids and HW vapors.
• IGNITABLE OR REACTIVE WASTES • Containers of hazardous waste that are ignitable or otherwise reactive are protected from sources of ignition or reaction, including but not limited to: open flames, smoking, sparks, and spontaneous ignition. Water-reactive wastes and oxidizers are separated from flammable and combustible liquids, and containers of flammable liquids are grounded.
• TRANSPORTATION • Department EVC is responsible for safely transporting waste containers from the HWAP to the HWSA using only government owned vehicles (GOVs). • Containers of HW are transported using equipment designed for the task, and containers are secured to pallets before moving the pallet. • No personnel at NAVSTA Rota are authorized to transport HW outside of the installation boundary or along public roadways.
SOP: HAZARDOUS WASTE ACCUMULATION POINT OPERATIONS
General Information
A Hazardous Waste Accumulation Point is a designated location at or near the point of generation where the activity (e.g., shop, site, work center) EVC has control of the site at all times. There are two compliance factors required to operate a HWAP; accumulation time and volume.
Responsibility
NAVSTA Rota PWD Environmental Division HWPM is responsible for overseeing HWAPs for all activities generating hazardous waste, ensuring EVCs and alternates are designated in writing, trained in HWAP procedures, and weekly inspections are conducted at HWAPs for compliance.
Environmental coordinators and alternates will coordinate with HWPM and fulfill duties required to manage hazardous waste, maintain a safe and secure HWAP, conduct weekly inspections and correct deficiencies.
Contractors performing work aboard NS Rota will coordinate with the designated contracting officer, DLA HW COR and HWPM for specific instructions prior to generating any hazardous waste.
Applicability
• All containers of hazardous waste.
• Containers of unknown or undetermined content will be presumed hazardous waste and managed as such until supporting documentation is provided.
Procedures
• Containers should be labeled with appropriated bilingual hazardous waste label, see example below.
• Containers are dated with the first day hazardous waste enters the container.
• EVCs are responsible to manage HWAPs according to standards stablished at Spanish FGS, Chapter 6.
• A limited volume of hazardous waste can be accumulated at each HWAP. o No more than 208 liters (55 gallons) of each type of hazardous waste stream. o No more than 1 liter (1 quart) of acute hazardous waste.
• The HWAP must be operated to provide appropriate segregation for different waste streams, including those that are chemically incompatible
• The HWAP is required to have the following equipment on site where applicable: • Portable fire extinguisher and fire control equipment • Emergency eyewash station • Personal protective equipment • Spill kit with adequate materials for the type and quantity of HW stored
• Each HWAP will have warning signs appropriate for the waste being accumulated at that site and a bilingual “Hazardous Waste Accumulation Point” sign posted at the site location • Each HWAP must have site-specific spill kits • Each HWAP Site Coordinator will conduct written weekly inspections using the NS Rota HWAP Inspection Checklist and retain this record in the EV Continuity binder. The NS Rota HWAP Inspection Checklist is below:
WEEKLY ENVIRONMENTAL INSPECTIONS Building/Area: Date:
Coordinator/Inspector:
Unit/Department/Tenant/Assessed:
Environmental Inspection Checklist YES NO N/A Hazardous Material: 1. Are hazardous material lockers properly maintained and marked with chemical warning signs for each hazardous material stored inside? 2. Are Safety Data Sheets (SDSs) at storage locations for each hazardous material available? 3. Are SDSs bilingual (English/Spanish) if local national workers are present?
4. Does each work center maintain a file of SDSs for each hazardous material procured, stored, or used at the work center? 5. Are all hazardous materials approved in the Shop Authorized Use List (AUL)?
6. Do all containers of hazardous material have manufacturer-generated warning labels or Hazardous Chemical Warning signs? 7. Are labels in Spanish if Spanish workers are present?
8. Are materials listed in FGS Chapter R 5 – Table 5.3 prohibited or restricted in the work center, with the exception of mission critical materials? Hazardous Waste: 9. Do Hazardous Waste (HW) Generators identify and characterize wastes using a Hazardous Waste Profile Sheet (HWPS) per waste stream? 10. Do HW Generators maintain an audit trail of HW from the point of generation to disposal? (i.e., ETID – the Electronic Turn-In Document from DLA’s online program ) 11. Is the Hazardous Waste Accumulation Point (HWAP) designed and operated to provide appropriate segregation for different waste streams, including those that are chemically incompatible? 12. Does HWAP have warning signs (i.e.: flammable, corrosive…) for the waste accumulated inside? 13. Does HW Generator maintain recordkeeping: ETID 1348-1A (5 years), HWPS (5 years), Inspection (3 years), Training Records (3 years, after finishing duty)? 14. Are all containers at the HWAP closed, except when adding or removing waste?
15. Are containers of flammable liquids grounded when transferring flammable liquids?
16. Are all containers inside the HWAP marked with a HW bilingual label (Eng/Spanish)? 17. Is HWAP inspected weekly for leaking and deteriorating containers? Are secondary containment systems inspected for defects and emptied of accumulated releases or retained storm water? 18. Does secondary containment meet sufficient capacity to contain 10% of the volume of the stored containers, or the volume of the largest container, whichever is greater? 19. If a HW container has reached the 4 month storage limit at the HWAP, has the HW Generator prepared the necessary disposal documents? 20. Mark the number of containers for each waste stream below:
POL Other (Identify Below)
Spill Response: 21. Are spill kits available in all areas where there are hazardous materials or hazardous waste storage or handling? 22. Is there an up-to-date spill kit inventory maintained and displayed with each spill kit? 23. Have all spills over the past inspection period been properly cleaned up, and any used spill response material been disposed properly? 24. Are secondary containment structures for tanks, drums, hazardous waste, and hazardous materials free of defects, leaks, spills, cracks, and debris? 25. Are all personnel that use, handle or store HM or HW trained to respond to a spill? (HSIRM training offered annually in January/February by the PWD Environmental office) Solid Waste & Recycling: 26. Are recyclables being separated from solid waste at the facility?
27. Are the building janitors collecting recyclables from the inside of the buildings, and disposing them in the proper exterior recycling containers? 28. Have all excess pallets been taken to a pallet collection location?
Water/Waste Water/Storm Water: 29. Are water conservation practices followed at your facility?
30. Is rain water that has collected in secondary containment structures inspected to ensure that no visible oily sheen is present prior to opening the valve to discharge? 31. Are oil-water separator(s) in good condition and maintained properly?
32. Are back flow preventers installed on all faucets used with hoses?
33. Are all non-storm water pipelines discharging to the storm water system (ditches, culverts, soil or surface water) removed or connected to the sewer system? EMS/Environmental Compliance/Training: 34. Is the Dept. Environmental Continuity Binder up to date? (ie, EV Policy, EC Designation Form, Weekly Inspection Checklists, Training Records, ETID Turn- in, Hazardous Waste Profile Sheets (HWPS), Spill Plan, SOPs? 35. Are Environmental trainings used to increase environmental awareness and documented? - Hazardous Waste Facility Operations Course
- Hazardous Waste Facility Generator Course (English)
- Hazardous Waste Facility Generator Course (Spanish)
- Spill Response HSIRM/Refresher
- ECATTs Module: ”Environmental Management System (EMS): NAVSTA Rota” Website Login: https://navfac.ecatts.com Password: navfac Can you answer the Environmental awareness questions? Are you aware of the NAVSTA Rota Environmental Policy?
What does the NAVSTA Rota Environmental Policy mean to you? (Commitment to the Environment, Compliance, Pollution Prevention, Continual Improvement) Have you had environmental training? (ICR Indoctrination Class, ECATTS, other means) What are the three main environmental goals of the environmental program? 1) Water Conservation 2) Increase Recycling 3) Properly manage hazardous waste (other goals are: prevent spills, prevent pollution, and choose green products) What do you do in the event of a spill or environmental emergency? (call 911 from landline, 727-2911 from a government cell, or 956-822-911 from a personal cell) Comments:
Corrective Actions (for each noncompliant item, please describe type and completion date of corrective actions)
Yes: Compliance No: Noncompliance N/A: Not Applicable Bilingual Label
SOP: HAZARDOUS WASTE STORAGE AREA OPERATIONS
General Information
The Hazardous Waste Storage Area is located at Building 1811 and meets the location and design requirements of FGS-Spain. It serves as the secure location where HW is managed prior to shipment offsite for treatment or disposal. Hazardous wastes are transported off-site for disposal within 180 days (six months) of being received at the HWSA. Access is restricted except during operating hours from 07:30 – 16:30 Monday through Friday.
Applicability
• Hazardous Waste Program Manager • Hazardous Waste Storage Area Operator/Contractor • Environmental coordinators
Procedures
Emergency • In the event of an Emergency, call the Fire Department at 911. • An internal communication or alarm system capable of providing immediate emergency instruction (voice or signal) will be activated in the event of an incident. • Notify the HWPM of the nature of the emergency at 727 1421. HWPM will follow up to determine the cause, corrective action, and implement procedures to prevent future occurrences. • HWSA Contractor will ensure portable fire extinguishers, fire control equipment appropriate to the material in storage, spill control equipment, and decontamination equipment are present and in good condition at all times.
Receiving Waste • EV Coordinators contact 727- 4100 to coordinate with HWSA Contractor after receiving approval from DLA HW COR and ETID signature from HWPM. • HWSA Contractor will record the waste control numbers into the Hazardous Waste Log. • HWSA Contractor with EVCs will weigh and record weight of each waste container or ETID. • HWSA Contractor will segregate waste container by hazard class and place containers in the properly designated locations while in storage and awaiting shipment.
Inspections and Recordkeeping • HWSA Contractor will inspect areas subject to spills (loading and unloading areas) daily when in use. • HWSA Contractor will inspect the HWSA weekly for leaks and deteriorating containers and containment systems. Secondary containment systems shall be emptied of accumulated releases or storm water and inspected for defects. • HWSA Contractor will inspect the HWSA monthly for malfunctions, deterioration, and discharges that may cause, or result in, a release of HW constituents to the environment or threat to human health. • HWPM will conduct an annual inspection of all equipment and areas involved in storage and handling of HW, including all containers and container storage areas, all monitoring equipment, safety and emergency equipment, security devices, and operating and structural equipment (such as dikes and sump pumps) that are important to preventing, detecting, or responding to environmental threats or human health hazards.
Safety and Security • HWSA personnel will ensure that only authorized persons enter the HWSA and that they are escorted. • HWSA personnel will ensure the gates are secured and locked before leaving the HWSA unattended.
• A sign with the words "Danger Unauthorized Personnel Keep Out," must be posted at each entrance to the HWSA in sufficient numbers to be seen from any approach to the HWSA. • Flammable liquid containers will be grounded or storage in grounded locker areas. • All PPE will be inspected and maintained according to procedures developed by the NAVSTA Safety Officer and DLA HW Contract specifications. • All respiratory protective equipment will be inspected and maintained according to a site-specific respiratory protective clothing procedure. • Bulging containers under active pressure will be treated as an emergency. • During emergencies, HWSA personnel will wear adequate PPE with back-up personnel on-site, as directed by the NAVSTA Duty CDO.
SOP: HW Turn in Procedures
General Information
Hazardous waste must be turned in for disposal by the ECs when one 55 gallon container reach the limit of 90% of capacity at the HWAP. The hazardous waste requires three forms of documentation prior to disposal; the Hazardous Waste Profile Sheet and an ETID or DD Form 1348-1A (examples below), and appropriate Safety Data Sheets (SDS’s).
Applicability
• Hazardous Waste Program Manager • Defense Logistics Agency HW COR • Environmental coordinators • HWSA Contractor
Procedures
• EV Coordinator will create a HWPS for each hazardous waste stream. The information from the HWPS is used to complete the ETID/1348-1A. A HWPS should be reviewed annually to ensure accuracy. • DLA recommends registered users to upload disposal data using Electronic Turn In Document (ETIDS) System. First time users must register at DLADS web site [http://www.dispositionservices.dla.mil/etid/Pages/default.aspx]. • DLA reviews for correctness, consults with the EVCs if necessary, then approves and accepts the waste for disposal. • Route approved disposal documents to EVCs for signature, who will send it to HWPM to obtain digitally signature for ETID. • EVCs may contact HWSA Operator at 727-4100 to arrange transfer of waste containers from HWAP to the HWSA. Containers of HW must meet the ADR transportation requirements. • HWSA Contractor receives only pre-approved waste containers for management and disposition. • See the following for guidance on turn-in procedures from transient and home ported ships.
SOPA (COMNAVACT Spain Instruction 3170.1) (Reviewed by HWPM by Jan 2018)
EMERGENCY OIL SPILLS, CALL 911
NAVSTA ROTA, Environmental Guide for Hazardous Material Offload for Transient and Homeport Ships
In accordance with OPNAV Ships forces do not generate “Hazardous Waste”, the facility where the ships are homeported are the generators. Ship’s forces manage hazardous materials. However, once the excess HM is placed onto the pier, all waste regulations are applicable. It is ship’s forces responsibility to ensure the use of DOT/ADR approved and proper containers, they are properly labeled and the material is properly characterized and documented. All hazmat offload must be coordinated with NAVSTA Hazardous Waste Manager, NAVFAC PE Environmental Office, phone# 727 1421 or email: [email protected] The Point of Generation identifies both the date and place a material first become subject to the regulations OR when the waste if offloaded from the ship with the intention of disposal. Hazardous Material at NAVSTA Rota such as Petroleum, Oil and Lubricants; all type of batteries and fluorescent lamps, empty POL drums are to be consider part of the recycling program and must be
coordinated with NAVSTA Recycling Program Manager, NAVFAC PW Environmental Office, phone# 727 2123
Procedures for HM Offload for Transient Ships: Request permission to offload HM from COMSERVFORSIXTHFLT, Info NAVSTA Rota SP/PW N7N2/N41F/PORT//IAW CONSERVFORSIXTHFLT INST 4000.1U Paragraph 2004. See page 20-A-1-1 of the instruction for a sample message request. COMSERVFORSIXTHFLT will approve/direct the offload/transfer via e-mail and provide document numbers for labeling and DD Form 1348-1A preparation. NAVFAC EURAFSWA, Environmental will not take action on the request until COMSERVFORSIXTHFLT provides the approval documents.
The following general procedures apply for HM offload at NAVSTA Rota: 1 – Ship must send message for offload HM to COMSERVFORSIXTHFLT Naples 2 – CTF63 Naples will approve funds and provide authorized documents for the offload. Documents will be sent to requested Ship and NAVFAC HWPM via e-mail. 3 – Document(s) needed for turn-in HM at NAVSTA Rota: Approved DD Form 1348-1A SDSs for the HM to be offload Hazardous Waste Profile Sheet (per waste stream) Before any document is attached to a DOT/ADR approved container, the Ship Commanding Officer’s authorized representative will inspect the DD Form 1348-1A to ensure it is properly completed and signed, has the correct SDS(s) attached, and the corresponding container has been properly labeled with Ship’s name, document number, technical name/nomenclature and hazards associated with it. For all turn-in documents, the proper shipping name must be in English, as per ADR requirements in Europe (the DLA Disposition Services, HW disposal contract for Spain provides names for each contract line item number (CLIN) description) 4 – DD forms 1348-1A will be prepared in accordance with DoD 4160.21M, identifying HM to be disposed according to message. Forms must be prepared according to COMSERVFORSIXTHFLT 4000.1U, Paragraph 2004, (1) g. 5 – SDS (s) are required to be affixed to each approved DD Form 1348-1A 6 – All drums will be labeled within bi-lingual (English/Spanish) labels available at NAVFAC EURAFSWA, PW Environmental OR by purchasing them from DLA Disposition Services HW Contract. 7 - The DLA Disposition Services HW CLIN’s provided in the contract are priced per kilogram and euros. All Ships must weigh each drum to ascertain the correct contract charge. 8- The contract does not have a CLIN for offload/disposal transport from the Pier to the NAVSTA Hazardous Waste Storage Area Building# 1811. A request for transportation is needed at the pre- deployment briefings to NAVFAC PW, BSVE or contacting NAVSTA Rota, NAVSUP VI Fleet Support Office 9– No HM will be offloaded until inspected and approved by NAVFAC EURAFSWA PW Environmental HW Manager and/or NAVSUP Afloat Technician.
HM Offload from Homeport Ships: 1 – Afloat Commanding Officers shall: a. Accept liability for HM misidentification by ship’s force b. Provide to NAVFAC PW Environmental Division the name and phone number of the Afloat Environmental Protection Coordinator (AEPC) and Alternate upon assignment c. Designate in writing the Ship’s Hazardous Material Coordinator, reference (b), and an Alternate Coordinator(s), an E6 or senior with Hazardous Waste Facility Operator Training coordinated yearly at NAVSTA Rota, and annually thereafter. 2 – Afloat Environmental Protection Coordinator (AEPC) will: a. Be familiar with NAVSTA Rota Environmental Final Governing Standards, Chapter 6 for HM/W Offload requirements and regulations b. Indoctrinate new personnel on the requirements of this SOP during check-in, and document training. Training records are subject to inspection to verify adequate personnel training is provided by the command
c. Receive DLA Disposition Services training to proper fill in necessary turn in documents for HM Offloads, using DLA website, AMPS/ETID (https://business.dla.mil/landing/ds.jsp) (e.i, DD Form 1348-1A & Hazardous Waste Profile Sheet) d. Containerize in approved DOT/ADR container all HM to be offload e. Prepare ETID DD Form 1348-1A and Hazardous Waste Profile Sheet for HM offloads f. Notify and Coordinate with NAVSUP Afloat Technician or NAVFAC PW Environmental onboard HM Inspections before offloading HM to Pier g. Use forklift operators to prepare hazmat containers for transportation h. Transfer HM from Pier to NAVSTA Hazardous Waste Storage Area, Building# 1811 3 – NAVFAC PW Environmental a. Provides necessary support and technical expertise to facilitate implementation of environmental hazardous material/waste programs b. Coordinate and Inspect HM along with NAVSUP Afloat Technician and/or AEPC for Ship’s HM offloads c. Verifies approved by DLA Disposition Services turn in documents (e.g., DD Form 13481-A, SDSs, Hazardous Waste Profile Sheet (HWPS) prior to acceptance of HM offloads d. Coordinate AEPC hazardous waste facility operator training and recertification thereafter e. Responsible for the general management of the Installation’s HM/W programs
Sample Waste Profile Sheet
Sample Turn-In Document
SOP: Disposal Procedures
General Information
Hazardous waste turned in at the HWSA is centrally managed for disposal by DLA Disposition Services. When the minimum requirements are met for a delivery order (DO), containers are prepared for shipment off-site in a timely manner. All wastes are removed prior to the waste accumulation start date reaching 180 days.
Applicability
• Defense Logistics Agency • HWSA Contractor • Hazardous Waste Program Manager
Procedures • DLA Disposition Services prepares the DO and schedules a pickup date. • DLA Disposition Services HW Contractor completes a Spanish Hazardous Waste Manifest(s). Only US military are authorized to sign the Spanish Hazardous Waste Manifest. • DLA Disposition Services Coordinate with local authorities for scheduled shipping from HWSA. • DLA Disposition Services HW Contractor and/or DLA HW COR will provide a completed shipping documents back to the HWPM for record retention.
Appendix B – HWAP and HWSA Locations
HWAPs and HWSAs
DEP./TENNANT Building Location
AMSS/AMC Bldg# 1989 HWAP Outside Blue Bin AMSS/AMC Bldg# 3231 HWAP Outside AIR OPS Bldg# 267 At fly line NAVSTA Bldg# 1811 HWSA
HOSPITAL Bldg# 1802 HWAP Inside FASTEUR Bldg# 514 ConnexBox Outside Compound
MWR Bldg# 231 Golf Course NCTAMS Bldg# 8 Outside HWAP NEX Bldg# 178 Auto Port
NMCB Bldg# 354 & Outside Alpha Company HWAP & HWAP Behind Bldg. PORT OPS Bldg# 189 HWAP Outside
NAVFAC FS Bldg# 61 HWAP Outside NAVFAC BSVE Bldg# 148 HWAP Inside
NAVFAC UEMB Bldg# 64 HWAP Outside
SECURITY Bldg# 3262 HWAP Outside FISC HAZMIN Bldg# 3336 HWAP Outside Warehouse
FISC FUELS Bldg# 612 HWAP Booster Pump House FISC FUELS Bldg# 3236 HWAP Aviation Fuels
CTF 68.4 Bldg# 160 HWAP Outside EODMU8 Bldg# 5 & 1672 HWAP Inside Hangar & Outside Bldg#148 NAVY MUNITIONS Bldg# 463 HWAP
NAVSEA Bldg# 555 HWAP Outside (Newimar Contractor) NEPMU7 Blldg# 3070 HWAP, locker inside USS ROSS Ship DDF Onboard HM
USS DONALD COOK Ship DDF Onboard HM
USS PORTER Ship DDF Onboard HM USS CARNEY Ship DDF Onboard HM
Appendix C – Waste Analysis Plan
NAVSTA ROTA
WASTE ANALYSIS PLAN (WAP)
WASTE ANALYSIS PLAN RECORD OF REVISIONS The following table is provided for tracking revisions to this plan. The plan will be updated as necessary to reflect changes in the waste streams generated and the procedures for waste characterization.
REVISION NAME AND DESCRIPTION OF PAGES NO. DATE TITLE SIGNATURE CHANGE AFFECTED
New Navy 6TH Fleet (N00061) Offload Binder Created HWPSs located at M. Carmen Master for VI Fleet HWMP 1 2016 Jan/Feb HWPSs for Ships Dominguez Ships office Updates in Navy 6th Fleet Updated HWPSs (N00061) M. Carmen Master for VI Fleet Offload 2 2017 July HWPS for Ships Dominguez Ships Binder
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TABLE OF CONTENTS SECTION
1 INTRODUCTION
2 CLASSIFICATION AND ANALYSIS OF WASTE FOR DISPOSAL
2.1 Laboratory Analysis of Waste for Disposal
3 TIMING AND FREQUENCY OF SAMPLING AND ANALYSIS
4 SAMPLING METHODS
5 CLASSIFICATION WORKFLOW FOR WASTE DISPOSAL
5.1 Unknown Waste Streams 5.2 Known Waste Streams
1. INTRODUCTION
This Waste Analysis Plan (WAP) is applicable to hazardous waste (HW) generated within Naval Station (NAVSTA) Rota. The purpose of this WAP is to describe how and when staff with responsibilities to manage HW identification, storage, and disposal will collect the information necessary to properly characterize wastes. The WAP contains procedures for testing HW and identifies analytical parameters and selection rationale, frequency of analysis, test methods, and sampling methods. The WAP satisfies the requirements of Section C6.3.3 of the FGS for Spain. 1.1 Glossary ADR – The European Agreement Concerning the International Carriage of Hazardous Goods by Road, conducted at Geneva on 30 September, 1957, as amended. Defense Logistics Agency (DLA) Disposition Service - The primary Department of Defense (DoD) agency providing HW disposal services to the installation. Department of Defense (DoD) Waste Generator – The installation, or activity on an installation, whose processes or actions generate HW. Disposal – Any activity listed in FGS Appendix B.2 (e.g., the discharge, deposit, injection, etc. of any HW into or on any land or water so that waste or constituent thereof may enter the environment). Proper disposal effectively mitigates hazards to human health and the environment. Environmental Coordinator (EC) – A person at the Department/Tenant Command assigned the operational responsibility for receiving, storing, inspecting and overseeing general management of their HWAP and managing others EV programs. Hazardous Waste (HW) – Any non-residential waste identified by an asterisk “*” in the “Hazardous Waste” column in FGS Appendix B.1. Excluding radioactive waste, waste from mining activities, air emissions, wastewater and recyclable materials such as used oil and batteries. Also materials that exhibit properties listed in Section 2.1 of this plan. Hazardous Waste Accumulation Point (HWAP) – A shop, site, or other work center where hazardous wastes are accumulated until removed to a Hazardous Waste Storage Area (HWSA). A HWAP may be used to accumulate no more than one 55 gallon ADR- approved container of HW from each waste stream. The HWAP must be at or near the point of generation and under the control of the operator. A HWAP is classed as temporary storage.
Hazardous Waste Generation Process – Any act or process that produces hazardous waste as defined in the Environmental Final Governing Standards (FGS). Hazardous Waste Program Manager (HWPM) – The person in the Environmental Department assigned overall general management/coordination of the HW program installation-wide.
Hazardous Waste Profile Sheet (HWPS) – A document which identifies and characterizes the waste by providing user's knowledge of the waste, and/or laboratory analysis, and details the physical, chemical, and other descriptive properties or processes which created the hazardous waste. Hazardous Waste Storage Area (HWSA) – One or more locations at DoD installation where HW is collected prior to shipment for treatment or disposal. A HWSA may store more than one 55 gallon ADR approved container per waste stream. A hazardous waste storage area is classed as temporary storage.
Unit Identification Code (UIC) - A six digit alphanumeric code which uniquely identifies each United States Department of Defense entity.
ACRONYMS AND ABBREVIATIONS
COR Contracting Officer Representative DLA Defense Logistics Agency EC European Council
EVC Environmental Coordinator EWC European Waste Catalogue HW Hazardous Waste HWAP Hazardous Waste Accumulation Point HWPM Hazardous Waste Program Manager
HWPS Hazardous Waste Profile Sheet
HWSA Hazardous Waste Storage Area NAVSTA Naval Station WAP Waste Analysis Plan
2. CLASSIFICATION AND ANALYSIS OF WASTE FOR DISPOSAL 2.1 Laboratory Analysis of Waste for Disposal To the extent possible, information regarding the classification of waste should be obtained from knowledge of the HW generating process (e.g. painting, degreasing, etc.) and the materials used in the process (e.g. solvents, water, blast media, paints, etc.). Sources of information should include manufacturer’s specifications, Safety Data Sheets, etc. Laboratory analysis of waste will occur only as necessary and if any of the following conditions are met:
1. When insufficient information is provided to identify any of the properties of HW defined in Annex III of EC Directive 91\689\EEC or to assign a European Waste Catalog (EWC) number.
2. When insufficient information is provided to prepare or comply with ADR or Spanish transportation requirements.
3. When insufficient data is present on the Hazardous Waste Profile Sheet (HWPS) to properly manifest and treat/dispose of the waste.
4. When a waste is unknown.
Additional laboratory analysis is necessary only when available information is not sufficient to classify the waste. Laboratory analysis is selected to complement existing information regarding the waste, in cooperation with the Hazardous Waste Program Manager (HWPM), Environmental Coordinator (EVC) and DLA HW COR. Laboratory analysis of waste for disposal purposes must be performed by an analytical laboratory with appropriate certifications for each of their methods for characterization of waste as inert, nonhazardous, or hazardous in Andalusia. NAVSTA DLA Disposition Services HW Contract has CLIN(s) for Laboratory Services to identify hazardous waste. The combination of existing information and laboratory analysis results must describe and quantify the following chemical and physical parameters for classification:
Non-liquid waste analysis: Flash point, asbestos content and asbestos classification, concentration of total organic carbon, pH, acid neutralization capacity and total concentration of benzene, toluene, ethylbenzene, xylenes, polychlorinated biphenyl, total petroleum hydrocarbon, and polycyclic aromatic hydrocarbons. Analysis of leachate obtained from non-liquid waste: Total concentration of heavy metals (As, Ba, Cd, Total Cr, Cu, Hg, Mo, Ni, Pb, Sb, Zn), chloride, fluoride, sulphate, cyanide, phenols, and dissolved concentration of organic carbon.
3. TIMING AND FREQUENCY OF SAMPLING AND ANALYSIS Known waste streams do not typically need to be analyzed. However, the EVC must provide annual updates to the HWPSs. EVCs and HW generating units shall also meet with Defense Logistics Agency (DLA) Disposition Services Contracting Officer’s Representative (COR) and HW contractor for concurrence with all profiles. If an EVC observes that a known existing waste stream appears to be different from the waste stream received in the past, or if there is a doubt, the EVC will implement the workflow described in Section 5.1 of this WAP. If a waste received at the Hazardous Waste Storage Area (HWSA) does not match the accompanying documentation, the waste will be rejected and the workflow described in Section 5.1 of this WAP shall be implemented. Rejected waste will be corrected and returned to the HWSA within 48 hours. The HW Contractor managing the HWSA will log and track rejection notice and follow up with notice if waste is not returned in 48 hours. All rejection notices will be notify to the DLA HW COR and the HWPM.
4. SAMPLING METHODS
Sampling of HW for laboratory analysis is always performed by the DLA Disposition Services HW disposal contractor.
Hazardous waste samples will be collected using standard collection protocols specified in the standards established by the Standard Methods for Examination of Water and Wastewater (SMWW)6, the U.S. Environmental Protection Agency (EPA), and the Spanish “Entidad Nacional de Acreditación (ENAC)” as applicable to the laboratory analysis methodology for classification of waste. The DLA Disposition Services HW disposal contractor shall obtain a representative sample. A representative sample is one that is small enough to be transported conveniently and yet large enough for analytical purposes while still accurately representing the material sampled. Additionally, a representative sample is one where the proportions or concentrations of all pertinent components will be approximately the same as in the material being sampled, and that the sample is handled and preserved in such a way that no significant changes in composition occur before laboratory analysis is conducted. Representative samples must be collected using decontaminated or single-use sampling equipment as well as all necessary personal protection equipment (PPE). Sample containers must be new, sterile, and preferably provided by the analytical laboratory, with all the necessary preserves specific to the analytical laboratory methods. When applicable, cooling and other sampling preservation measures must be implemented to ensure that the sample(s) composition does not vary or become contaminated during transportation. Before shipment, the DLA Disposition Services HW disposal contractor must ensure a chain of custody of the material sample is prepared and maintained during transport to the analytical laboratory ensuring all signed COC copies are forwarded to the DLA HW COR. 6 Standard Methods for the Examination of Water and Wastewater, 2010. 5. CLASSIFICATION WORKFLOW FOR WASTE DISPOSAL
5.1 Unknown Waste Streams Unknown waste streams will require analysis if the DOD Generator’s (hereinafter referred to as the generator) knowledge is inadequate to characterize the waste. In the event that the generator cannot provide enough information for characterization of the waste, the following workflow is implemented:
1. When an unknown waste is discovered, the generator of the waste contacts the EVC designated for its Department or Tenant Command in order to close or containerize the waste and move it to a designated Hazardous Waste Accumulation Point (HWAP).
2. Once the unknown waste is contained, it is labeled using a standard HW label. The label must indicate, at minimum, the generator’s Unit Identification Code (UIC), generator details, the date the container was closed and that the waste is “Unknown, pending analysis”. If unknown is an aqueous liquid, the EVC shall ensure proper secondary containment is available for ADR/DOT container. The EVC will ensure the unknown is properly stored with all pertinent information, then logged into the HW Log Operating record for tracking purposes.
3. When an unknown waste is discovered, the EVC will prepare the ETID/DD Form 1348-1A. The HWPM obtains a document authorization number for all NAVSTA Departments to be included on the ETID/DD Form 1348-1A. In case the waste is generated from a Tenant Command, the HWPM ensures their DODAAC (Department of Defense Address Activity Code) will be assigned to the document number.
4. The Environmental Coordinator will submit the ETID/DD Form 1348-1A to the DLA HW COR.
5. DLA HW Contractor will receive ETID/DD Form 1348-1A from EV Coordinator for laboratory analysis of the unknown waste using the appropriate Contract Line Item Number (CLIN) for identification of unknown waste for disposal classification.
6. The DLA Disposition Services HW contractor at the HWAP will collect a representative sample of the unknown waste and sends it to the analytical laboratory for analysis and disposal classification. The Government may also request a split sample for results from another lab if required. The outcome of the analysis is a certificate that indicates the classification of the unknown waste for disposal purposes (inert, non-hazardous or hazardous).
7. Using the certified waste classification provided by analytical laboratory, the DLA HW contractor prepares a new HWPS. The HWPS is received by the DLA HW COR, who sends it back to the EVC that has custody of the unknown waste.
8. If the unknown waste is a HW, the EVC will prepare a new ETID/DD 1348-1A using the new HWPS and generates a new document authorization form. 9. Once all turn-in documents are complete, the HWPM ensures the EVC sends the previously unknown waste to the HWSA following Hazardous Waste Management Plan (HWMP) Standard Operating Procedure (SOP) – Hazardous Waste Disposal.
5.2 Known Waste Streams
Known waste streams do not typically need to be analyzed. However, the EVCs must provide annual updates to the HWPS and disseminate to pertinent Department HW Continuity Binder, the DLA Disposition Services HW COR, the DLA Disposition Services HW contractor and the HWPM. An update to the HWPS is also required any time that a HW generating process changes. If it is discovered that there is insufficient information regarding the process change to characterize the waste, the procedures in Section 5.1 of this WAP may be required.