Environmental Management Procedure (EMP) Subject: Hazardous Waste Accumulation Facility (HWAF) Operations

Transcription

1 Environmental Management Procedure (EMP) Subject: Hazardous Waste Accumulation Facility (HWAF) Operations 1. Purpose: This EMP establishes the procedures for the operation of the HWAF. 2. Document Control: This is a controlled document. Controlled documents are updated as required, reviewed at least annually, and re-dated if changed. Any documents to include blank forms appearing in paper form are not controlled and should be checked against the file version prior to use on the: 3. References: JBLE Eustis Environmental website: A. JBLE-I , Environmental Management B. EMP Dictionary 4. Scope: This EMP applies to all Activities and personnel, including military, civilians, vendors, suppliers, and contractor personnel who enter JBLE-Eustis. The definition of an Activity can be found in JBLE I Roles and Responsibilities: A. The Civil Engineer Directorate (CED); Environmental (CEIE) operates the HWAF. B. HWAF Operations Officer will: (1). Coordinate with the Hazardous Waste Program Manager on policy and regulatory matters to ensure compliance. (2). Coordinates with the HWAF Manager to ensure smooth operations of the HWAF. (3). Ensures quality assurance of pending shipments utilizing advance copies of delivery orders is accomplished. (4). Ensures waste shipments are done within the regulatory 90 day time-frame. (5). Ensures all shipping documents, which include Manifests, Land Disposal Restriction Notification Forms, Delivery Orders, and other documents are correct before accepting and signing them after shipments are made. (6). Ensures all shipping documents are prepared correctly and in a timely manner. (7). Ensures all required documents and facilities are prepared for external inspectors (Local, State Federal). (8). Ensures all supply requirements are identified and proper documents are prepared and submitted for the continual operation of the facilities, also ensure that funds are obligated in a timely manner. (9). Ensures all Multi-Media Inspections (Self-Audits) of the HWAF are accomplished in a timely manner. (10). Ensures all shipping documents are processed and ready for data entries within 25 days of the shipment. EMP Page -1

2 (11). Coordinates the funding obligation for the collection of used oil and off-specification fuel is accomplished. (12). Ensures used oil and off-specification fuel from the activities meet all regulatory standards. (13). Coordinates special collection of used oil from buildings being demolished, is for tanks being filled in placed. (14). Conducts used oil quality assurance at least once a quarter. (15). Maintain good customer relations by: (a). Responding to all telephonic inquiries relating to compliance issues. (b). Responding all inquiries relating to compliance issues, while on site visits. (c). Assisting Activity personnel in preparing for any and all inspections. C. HWAF Manager will: (1). Adhere to all Federal, State, and local laws and regulations in the management of hazardous waste. (2). Coordinates with the Hazardous Waste Policy Manager on: (a). Policy and regulatory matters. (b). Sampling and analytical results. (c). Preparing and updating of waste profiles. (3). Coordinates with the HWAF Operations Manager on facility matters. (4). Transport hazardous and nonhazardous waste from facilities located on Ft. Eustis to the Hazardous Waste Accumulation Facility B1208. (5). Process waste & documentation which includes weighing all containers, repackaging or over packing if needed, properly label, insure that what is in the containers match that on the paperwork, put all information into log books. (6). Maintains a computer database to track all transactions of hazardous and nonhazardous waste disposal. Assist in the daily functions with profiles, manifests, bi-annual reports and ongoing site inspections for the facility. (7). After weighing and assigning tracking numbers to the containers, cost information is determined and then put on the shipping document (1348-1A). The cost data from the 1348-A is put on the FEVA Form At the end of each month the information is entered into HWAF s computer and the forms are taken to Resources Flight for processing. (8). Maintains a tracking log of all containers in the field. Issue containers which may include finding out the right waste description and profile number so labeling information can be assigned to each container. Assigning a tracking number to each container. Using a computer to print out a Container Contents Log (CCL) for each waste. (9). Tracks inventory for both facilities and order new containers when supply is low. Unloading & storage of new containers. EMP Page -2

3 (10). Reviews Materiel Safety Data Sheet (MSDS) information and work closely with field personnel to determine what waste is being generated. Sometimes chemical companies have to be contacted to ask for MSDS. (11). Data entry of drums issued and returned dates for these containers on a weekly basis. (12). Performs site inspections of all accumulation sites during pickups. (13). Housekeeping ensuring that the facility is maintained inside and out. (14). Performs Grounds maintenance and lawn care, weed control and landscaping when needed. (15). Performs cylinder recycling when needed. (Hand-held propane and ether bottles). Uses a device that removes excess gas and extracts the needle. The steel is then recycled. (16). Operates and maintains an off-specification fuel recycling program. When containers of offspecification fuels are turned in they are pumped into a 500 gallon holding tank. A fuel recovery company then sends a truck to pump put the tank. (17). Performs mandatory weekly site inspections of the HWAF. (18). Perform forklift operations when needed. (19). Works closely with lab personnel to pull samples of waste to be analyzed. Reviewing sample results when completed and identifying profiles to match the findings. (20). Prepares all waste for ship out before 90 day date expires. Work closely with the DLA Disposition Services, Norfolk personnel and waste disposal contractor. (21). Assists DLA Disposition Services, Norfolk transporter during waste shipments (Staging containers, comparing container count with manifest, loading containers, etc.). (22). Pickup and issue of recyclable oil and fuel filter containers to sites. (23). File MSDS, shipping documents, profiles and sampling information. (24). Pickup of Found on Post (FOP) wastes items that have been abandoned in dumpsters, left by roadsides or buildings, found in lockers or cabinets at closed facilities. (a). Proper procedure is to contact post Military Police to file a report. (b). Next is to determine if the waste is nonhazardous or hazardous and package it for shipment. Sometimes this is a difficult matter, especially if the container does not have a readable label. (c). In this case a sample must be sent to the lab and an investigation is needed to determine the contents. D. Activities will: (1). Either turn-in wastes directly to the HWAF or coordinate shipments of wastes with the HWAF to include laboratory analysis, container numbering, material profiling, manifesting, Land Disposal Restriction (LDR) approval, etc. (2). Reimburse the installation for HWAF operational over head as required. EMP Page -3

4 6. Procedures: EMP (3). Reimburse HWAF for all containers and labels issued; and other charges as required, i.e., sampling. The HWC, UEC, or AEC must contact the HWAF to schedule the appropriate appointment. Other personnel are not allowed to schedule appointments. (4). Unique one-time waste generation from Activities which do not routinely generate HWs or NHWs must submit a memorandum to the CEIE stating why this is a unique event signed by the Commander or Director having AEC appointment authority. The Commander or Director will sign all documents in the absence of an AEC. This action cannot be delegated to subordinates. (5). Activities having TSSs, SASs or NHSs which do not have an AEC, HWC, or UEC must submit a memorandum to the CEIE stating why an AEC, HWC, or UEC has not been appointed and trained signed by the Commander or Director having AEC appointment authority. The Commander or Director will sign all documents in the absence of an AEC. This action cannot be delegated to subordinates. A. General HWAF Operations: (1). Location and Hours of Operation: (a). HWAF is located in Building 1208 and the office is in Building (b). HWAF is open Monday through Friday from 0800 to 1500 hours. (c). Hours of operation are subject to change without notice due to mission requirements. HWAF is closed on all federal holidays and the Friday after Thanksgiving. If you cannot contact the HWAF and need an immediate answer, call CEIE. (2). All scheduling of appointments must be made through the HWAF, and should be in writing or Fax ( ). Appointments for services must be made at least the number of work days in advance as indicated below: (a). Delivery of containers and pick up of wastes: 3 days (b). Review and assistance with Waste Description Logs and Turn-in documents: 3 days (c). Review of material profiles: 3 days (d). Review of shipping documents, LDRs, and manifest signing: 5 days (e). Approval of Laboratories, Transporters, and TSDFs: 30 days (3). Large Quantity Generator (LQG) requirements must be met; and all HWs and UWs must be disposed within the appropriate time limits. (4). The HWAF staff is there to assist you; however they will not do your work for you. B. Generating Activities Utilizing the HWAF for Waste Turn-ins: (1). Schedule the appropriate appointment: (a). The HWAF will issue, deliver, and pickup containers of wastes from approved TSSs, SASs, and NHSs only. (b). Activities without approved sites must schedule an appointment and deliver wastes to the HWAF. EMP Page -4

5 (c). HWCs or AECs which fail to keep a scheduled appointment will have to schedule and deliver the wastes to the HWAF. If this causes a violation of the site time limits, the appropriate Commander or Director will be notified. (2). Issue and delivery of containers: (a). The HWC, UEC, or AEC must be present during the scheduled delivery or the scheduled service will be terminated and will be noted on a Pickup inspection report. (b). All Activities must have a Waste Description Log (WDL) approved for each waste prior to issue of containers. Activities should schedule an appointment to have their Waste Description Logs approved prior to requesting containers. (c). The HWAF will also issue a partially completed Container Contents Log (CCL) for each container. Items 1, 2, 4, 6, 8, 9, 10, 11, 12, 13, 14, 16, and 19 will normally be completed at this time by the HWAF. (3). Pickup of Containers: (a). The HWC, UEC, or AEC must be present during the scheduled pickup or the scheduled service will be terminated and it will be noted on a Pickup inspection report. (b). Correctly completed CCL (EMP TAB 2) and DD Form A (EMP TAB 1) must be completed prior to scheduling an appointment for pickup. (c). If the HWAF vehicle cannot get reasonably close to the TSS or SAS for container loading, then the activity will move accepted containers to the HWAF pickup vehicle. The Activity may need to have additional personnel available to help move containers. (d). The HWAF staff will inspect all containers and conduct a site evaluation for compliance. (e). Containers will be opened during the inspection. Activity personnel will assist during this process and must bring appropriate Personal Protection Equipment. At a minimum this will include eye protection and gloves. (4). Rejections and Corrections: (a). Only AECs and HWCs can turn-in wastes. Trained Coordinators are the only personnel authorized to sign the turn-in documentation's certification (CCLs and DD Form As). This is an automatic rejection. (b). Containers failing to meet all turn-in requirements will be rejected. (c). On-the-spot corrections for some administrative requirements may be possible. (d). Activities that have containers rejected for any reason, will have the rejection noted on the Pickup inspection report. Activities receiving a repeated rejection; numerous on the spot corrections for a single turn-in; or always requiring corrections over multiple turn-ins will have this noted on the inspection report. The Commander/Director will be required to send the Corrective Action Report through the MSG Commander to CEIE. (e). Compliance site evaluations conducted during delivery or pickups by the HWAF staff will be IAW EMP EMP Page -5

6 (5). Reimbursement for HWAF services: Activities may be required to reimburse the Base for services provided by the HWAF. The procedures below will be utilized for this process: (a). Reimbursements will be recorded and paid by using FEVA Form , HWAF Reimbursable Log (EMP Tab 3). i. Cost of containers received. ii. Sampling. iii. Off-spec fuel charges. iv. Antifreeze recycling charges. v. Filters recycling charges vi. HWAF operational overhead rate (HWAF O/H). This per pound rate will be determined by CEIE based on HWAF volume and operational costs. (b). Reimbursements for DLA Disposition Services, Norfolk disposal charges will be recorded and paid by using DD Turn-in Form A. (c). This log will be closed by HWAF personnel and submitted to Resources Flight for transfer of funds. C. Generating Activities Not Utilizing the HWAF for Waste Turn-ins: (1). Generating Activities may seek permission or be directed by CEIE to contract for laboratory, transportation, and disposal services for the following reasons: (a). The Activity has unique mission requirements that prevent utilization of DLA Disposition Services, Norfolk contracts. This action requires DA approval. (b). Waste disposal is not available from DLA Disposition Services, Norfolk due to the type of waste. (c). Contractors with project specific wastes which require them to arrange for transportation and disposal. (d). Other circumstances, e.g., generating Activity s mismanagement, which prevents utilization of DLA Disposition Services, Norfolk contracts or may violate the 90-day accumulation limitation. (2). In all cases, the generating Activity assumes all generator and generating Activity s liabilities, costs, and regulatory responsibilities for compliance and proper management in addition to compliance with this regulation. The CEIE will impose significant limitations, management over site, and direction that will ensure installation compliance. (3). All generating Activities contracting these services must have the contracts reviewed and approved by Civil Engineer Division/Environmental Element. (a). Only CEIE approved laboratories, transporters and TSDFs will be used. (b). Activities will be required to fund laboratory, transporter, and TSDF audits contracted for or conducted by CEIE personnel as required. (c). The HWAF O/H rate will be applied to each manifest or bill of laden based on total shipping weight using FEVA Form EMP Page -6

7 (4). Contactors accumulating wastes at SASs will move the waste to the HWAF to meet the 3 day time limit while awaiting transportation. (a). All containers will have Container Contents Logs. (b). Transporter and TSDF will be identified or the waste management company handling the wastes will be identified prior to commencement of any waste generating processes. (c). Approximate ship date will be given. All HWs will by transported by day 80. If not, the HWAF will have the wastes transported and disposed at the contractor s expense. (5). Contractors will be responsible for: (a). Preparing the manifest and LDR. (b). Providing placards. (c). The 24 hour emergency response number for the manifest. (6). This requirement will be reviewed annually by CEIE for recurring requirements. (7). Proper Waste Stream management must be accomplished: (a). Activities must have an approved Waste Description Log for each line item (waste stream) on HW manifests or non-hazardous waste manifests/bills of lading prior to issue of a manifest document number. (b). Material profiles must be reviewed and approved by the HWAF prior to shipment. (8). Personnel authorized to sign manifests or shipping documents: (a). Each manifest must have 24-hour emergency response information. The installation does not provide this capability, therefore the activity must arrange for this service. (b). Manifest errors will be justification for the individual signing the manifest to be permanently removed from the authorized signature list and may incur other legal actions. Activities not having an authorized signature person will be required to schedule shipments with the HWAF in order to have the manifest signed. (9). Activities signing materials profiles, LDRs, and manifests will have up to date copies of the following regulations and references as a minimum: (a). 40 CFR (b). 49 CFR (c). Virginia Hazardous Waste Management Regulations. (d). North American Emergency Response Guidebook. (10). Correctly completed and certified Container Contents Logs (CCLs) must be delivered to the HWAF along with the signed legible copies of manifests, TSDF material profiles, analytical data, and LDRs within 2 working days of each shipment. EMP Page -7