BY ORDER OF THE AIR FORCE PAMPHLET 32-7043

SECRETARY OF THE AIR FORCE 1 NOVEMBER 1995

Civil Engineering

HAZARDOUS WASTE MANAGEMENT GUIDE

____________________________________________________________________________________________________

This pamphlet provides guidance for managing hazardous waste at Air Force installations to meet Federal, state, interstate,

Department of Defense (DoD), Air Force, and local environmental, worker safety, and transportation requirements. It helps

major commands (MAJCOM) implement AFI 32-7042, Solid and Hazardous Waste Compliance. MAJCOMs may adopt

all or portions of this guidance in order to meet the requirements of this AFI. Additionally, this guide assists in developing

basic training requirements for hazardous waste management for personnel at Air Force installations and their tenants,

including Air Force Reserve and Air National Guard units and members. This pamphlet applies to the Air National Guard

except as modified by supplemental instructions developed to meet the unique requirements of the Guard. This pamphlet is

not intended for direct use by installations in foreign countries, but sections could be adopted to provide guidance for Air

Force activities at those locations.

Paragraph

Chapter 1--Introduction

Purpose............................................................................................................................................................. 1.1

Background ...................................................................................................................................................... 1.2

Objectives......................................................................................................................................................... 1.3

Guide Layout .................................................................................................................................................... 1.4

Chapter 2--Overview of Hazardous Waste Regulations and Responsibilities

Background of Hazardous Waste Regulations and Responsibilities.................................................................... 2.1

Resource Conservation and Recovery Act (RCRA ............................................................................................. 2.2

Other Applicable Federal Laws and Regulations ............................................................................................... 2.3

DoD Directives and Air Force Policies.............................................................................................................. 2.4

State Regulations .............................................................................................................................................. 2.5

Local Regulations ............................................................................................................................................. 2.6

Roles and Responsibilities................................................................................................................................. 2.7

Chapter 3--Hazardous Waste Generation (Determination and Characterization)

Overview .......................................................................................................................................................... 3.1

Hazardous Waste Regulatory Process................................................................................................................ 3.2

Air Force Characterization Process ................................................................................................................... 3.3

Identification Substep........................................................................................................................................ 3.4

Description Substep .......................................................................................................................................... 3.5

Quantification Substep...................................................................................................................................... 3.6

Documentation.................................................................................................................................................. 3.7

Work Information Management System - Environmental Subsystem (WIMS-ES)............................................. 3.8

Chapter 4--Hazardous Waste Storage (Container Management, Generator Classification, and Accumulation

Management)

Overview .......................................................................................................................................................... 4.1

OPR: HQ USAF/CEV (Major John W. Coho) Pages: 142/Distribution: F

Certified by: HQ USAF/CEV (Col L. Dean Fox)
2 AFPAM 32-7043 1 November 1995

Paragraph

Container Management..................................................................................................................................... 4.2

Tank Management............................................................................................................................................ 4.3

Generator Classification.................................................................................................................................... 4.4

Accumulation Management .............................................................................................................................. 4.5

TSDF Documentation Requirements................................................................................................................. 4.6

Chapter 5--Hazardous Waste Disposal (Turn-In, Transport, and Disposal)

Overview .......................................................................................................................................................... 5.1

Turn-in ............................................................................................................................................................. 5.2

Transportation .................................................................................................................................................. 5.3

TSDF Selection................................................................................................................................................. 5.4

Forecasting Waste Disposal Requirements ........................................................................................................ 5.5

Transportation and Disposal Documentation..................................................................................................... 5.6

Air Force Documentation Requirements............................................................................................................ 5.7

Chapter 6--Emergency Procedures and Prevention

Overview .......................................................................................................................................................... 6.1

Preparedness Requirements............................................................................................................................... 6.2

Response Requirements..................................................................................................................................... 6.3

Incorporation of Requirements into Installation's HAZMAT Plan ..................................................................... 6.4

Emergency Coordinator Responsibilities........................................................................................................... 6.5

Toxic Chemical Release Reporting (EPA Form R) ............................................................................................ 6.6

Release Reporting and Emergency Notification (Incident Report....................................................................... 6.7

Chapter 7--Personnel Safety

Overview .......................................................................................................................................................... 7.1

Typical Hazards and Harms.............................................................................................................................. 7.2

How to Protect Yourself and Fellow Co-Workers .............................................................................................. 7.3

Safe Working Procedures.................................................................................................................................. 7.4

Additional Sources of Information .................................................................................................................... 7.5

Applicable AFOSH Standards........................................................................................................................... 7.6

Chapter 8--Training

Overview .......................................................................................................................................................... 8.1

Personnel Requiring Training ........................................................................................................................... 8.2

Training Frequency........................................................................................................................................... 8.3

Who Conducts Training.................................................................................................................................... 8.4

Air Force Training Programs............................................................................................................................ 8.5

Customizing Training....................................................................................................................................... 8.6

Hazard Communication Training...................................................................................................................... 8.7

Training Documentation................................................................................................................................... 8.8

Chapter 9--Waste Minimization

Overview .......................................................................................................................................................... 9.1

Air Force Pollution Prevention Program............................................................................................................ 9.2

Waste Minimization Hierarchy ......................................................................................................................... 9.3

Team Approach ................................................................................................................................................ 9.4

Benefits of Pollution Prevention........................................................................................................................ 9.5

Pollution Prevention Regulatory Requirements.................................................................................................. 9.6

Meeting Pollution Prevention Goals.................................................................................................................. 9.7

Quarterly Summaries........................................................................................................................................ 9.8

Chapter 10--Hazardous Waste Management Plan

Overview .......................................................................................................................................................... 10.1

Hazardous Waste Management Plan Elements.................................................................................................. 10.2
AFPAM 32-7043 1 November 1995 3

Page

Figures

1.1. Cradle-to-Grave Hazardous Waste Life-Cycle Management Process................................................................. 5

3.1. Generation Phase of Hazardous Waste Life-Cycle Management Process........................................................... 11

3.2. Hazardous Waste Profile Sheet (Front.............................................................................................................. 18

3.3. Hazardous Waste Profile Sheet (Back............................................................................................................... 19

4.1. Storage Phase of Hazardous Waste Life-Cycle.................................................................................................. 36

4.2. Accumulation Site Log and Instructions........................................................................................................... 42

5.1. Disposal Phase of Hazardous Waste Life-Cycle ................................................................................................ 55

5.2. Sample Air Force Form 2005, Issue/Turn-In Request....................................................................................... 61

5.3. Sample DD Form 1348-1, DoD Single Line Item Release/Receipt Document................................................... 63

5.4. Required EPA Marking for Containers of 110 Gallons or Less......................................................................... 65

5.5. Sample of Preprinted Marking Which Can Be Used to Meet EPA/DOT Requirements..................................... 65

5.6. Sample PCB Marking ...................................................................................................................................... 66

5.7. Sample Uniform Hazardous Waste Manifest .................................................................................................... 68

5.8. Sample Uniform Hazardous Waste Manifest Continuation Sheet...................................................................... 69

Tables

2.1. Overview of RCRA .......................................................................................................................................... 7

2.2. Federal Laws and Their Impact on Air Force Installations ............................................................................... 8

3.1. RCRA Specifications for Used Oil Burned for Energy Recovery....................................................................... 15

3.2. Hazardous Waste Profile Sheet Instructions ..................................................................................................... 20

3.3. Determination of Treatment Standards............................................................................................................. 24

3.4. Land Disposal Restrictions Subcategories for Characteristic Wastes................................................................. 25

3.5. Hazardous Waste Stream Inventory and Instructions........................................................................................ 26

3.6. Hazardous Waste Process Codes....................................................................................................................... 28

3.7. EPA Priority Pollutants.................................................................................................................................... 29

3.8. Typical Wastes Generated at Air Force Installations ........................................................................................ 30

4.1. Sample Hazardous Materials Table and Column Explanation .......................................................................... 37

4.2. Performance-Oriented Packaging Codes for Non-Bulk Packaging.................................................................... 38

5.1. Proper Shipping Description Guidelines........................................................................................................... 56

5.2. AF Form 2005, Issue/Turn-In Request Instructions.......................................................................................... 62

5.3. DD Form 1348-1, Disposal Turn-In Document Instructions............................................................................. 64

5.4. Placarding Requirements for Table 1 Hazardous Materials............................................................................... 66

5.5. Placarding Requirements for Table 2 Hazardous Materials............................................................................... 67

5.6. Hazardous Waste Manifest Instructions............................................................................................................ 70

5.7. Hazardous Waste Manifest (Continuation Sheet) Instructions .......................................................................... 74

5.8. RCRA Records and Corresponding Minimum Retention Periods...................................................................... 75

8.1. Hazardous Waste Training Requirements......................................................................................................... 89

8.2. Hazardous Waste Training Matrix ................................................................................................................... 91

9.1. Waste Minimization/Management Options Hierarchy ..................................................................................... 94

10.1. Information and Emergency Contacts............................................................................................................. 95

Attachments

1. Glossary of References, Abbreviations, Acronyms, and Terms ............................................................................ 98

2. Sample Hazardous Waste Management Plan....................................................................................................... 103

____________________________________________________________________________________________________

Chapter 1

INTRODUCTION

1.1. Purpose. This guide aids installation personnel

managing hazardous waste by identifying the Federal and

Air Force requirements, and providing guidance and

procedures to meet them. The Hazardous Waste

Management Guide (the Guide) does not apply to

radioactive wastes and the corresponding regulatory

policies.

1.2. Background. Within typical Air Force installations,

there are a diverse number of materials and procedures
4 AFPAM 32-7043 1 November 1995

which result in or generate hazardous wastes streams.

Once generated, the hazardous waste must be accumulated

or stored in appropriate containers or tanks. Within

prescribed time limits, the hazardous waste is turned in

and transported to an Environmental Protection Agency

(EPA) approved facility for treatment, storage, recycling,

or disposal. Hazardous waste management involves many

personnel throughout an installation, including generating

activities and handlers, personnel with oversight

responsibilities, accumulation point and site managers,

permitted storage facility managers, emergency

responders, bioenvironmental engineering services, and

the environmental manager.

1.2.1. Life-Cycle of Hazardous Waste. As seen in

figure 1.1, the hazardous waste life-cycle process consists

of three phases: Generation, Storage, and Disposal. To

help manage hazardous waste as it passes through the

three phases, the guide identifies seven process steps

(hazardous waste characterization, container/tank

management, generator classification, accumulation

management, turn-in, transportation, and disposal) and

six requirements that affect the entire hazardous waste

life-cycle (waste minimization, recordkeeping and

reporting, emergency procedures and prevention,

personnel safety, training, and the hazardous waste

management plan).

1.2.2. Importance of Hazardous Waste Management.

There are serious legal and environmental impacts

associated with deficient or insufficient hazardous waste

management. Legal impacts are straightforward,

specified by the numerous regulations and legislation,

resulting in both criminal and civil penalties.

Environmental impacts associated with hazardous waste

mismanagement are of a different nature, they extend

beyond the individual to society.

Historically, the impacts on the environment, from even

small accidental releases, have shown to be detrimental to

both human health and the environment.

1.2.3. Importance of Pollution Prevention. Reducing

hazardous waste should be an underlying concept

throughout the hazardous waste management process.

Further information on pollution prevention and waste

minimization is provided in chapter 9 of the guide.

1.3. Objectives. This Guide provides the user with a

broad understanding of the regulations, processes, and

procedure associated with cradle-to-grave hazardous waste

management and outlines the requirements for developing

a hazardous waste management plan.

1.4. Guide Layout. The Guide is structured in a

straightforward manner. Chapters 1 and 2 outline

background information. Chapters 3 through 10 follow

the hazardous waste life-cycle management process shown

in figure 1.1. These chapters identify the procedural

requirements associated with hazardous waste

management throughout the life-cycle process. If users

are unfamiliar with any of the terms or acronyms, they

should refer to attachment 1 for clarification. Attachment

2 provides an example of a hazardous waste management

plan and a waste analysis plan.

1.4.1. Federal Requirements. Most procedural chapters

conclude with a tabular summary of the pertinent Federal

requirements discussed in that chapter. The summary

includes the required element and corresponding CFR

citation, for convenient user reference.
AFPAM 32-7043 1 November 1995 5

GENERATION

 PHASE

STORAGE 

PHASE

DISPOSAL

PHASE

HAZARDOUS WASTE MANAGEMENT PLAN

EMERGENCY PROCEDURES & PREVENTION/PERSONNEL SAFETY/TRAINING

TRACKING - RECORDKEEPING & REPORTING

WASTE MINIMIZATION

INITIAL

ACCUMULATION

POINT (IAP)

ACCUMULATION

SITE (AS)

PERMITTED

FACILITY

SMALL QUANTITY

(SQ)

LARGE QUANTITY

(LQ)

CONDITIONALLY

EXEMPT (CE)

PERMITTED 

FACILITY (PF)

ACCUMULATION

MANAGEMENT

STEP

CHAP 3 CHAP 4 CHAP 4 CHAP 4

CHARACTERIZATION 

STEP

CONTAINER/TANK

MANAGEMENT 

STEP

IDENTIFICATION

(WAP)

DESCRIPTION

(HWPS)

QUANTITY

(HW I

SELECTION

MARKING

HANDLING

GENERATOR

CLASSIFICATION

STEP

WEIGHTING

FORMS

FUNDING

LOADING

MANIFEST

PLACARDING

ON-BASE

OFF-BASE

SELECTION

DRMO

DISPOSAL 

STEP

CHAP 5 CHAP 5

TRANSPORT

STEP

TURN-IN

STEP

CHAP 5

Figure 1.1. Cradle-to-Grave Hazardous Waste Life-Cycle Management Process.
6 AFPAM 32-7043 1 November 1995

____________________________________________________________________________________________________

Chapter 2

OVERVIEW OF HAZARDOUS WASTE REGULATIONS AND RESPONSIBILITIES

2.1. Background of Hazardous Waste Regulations and

Responsibilities. Regulation of hazardous waste

management evolved primarily from amendments to the

Solid Waste Disposal Act (SWDA), passed in 1965 to

focus on municipal waste disposal practices at sites such

as dumps and landfills. Before enactment of the Resource

Conservation and Recovery Act (RCRA) in 1976, there

were few Federal laws or standards regulating the

management of hazardous waste. Regulation of these

materials was primarily left up to the state and local

governments. The 1984 passage of the Hazardous and

Solid Waste Amendments (HSWA) of RCRA established

the current framework for hazardous waste management

requirements.

2.2. Resource Conservation and Recovery Act

(RCRA). RCRA directs the EPA to establish and enforce

regulations for the management of hazardous waste.

Federal regulations are promulgated through the Federal

Register and compiled annually into the Code of Federal

Regulations (CFR). Regulations define how a law or

statute's broad policy directives are to be implemented.

RCRA requirements are found in 40 CFR Parts 240

through 280. RCRA, as amended by Hazardous and Solid

Waste Amendments, consists of 10 Subtitles, A through J

(see table 2.1). Subtitle C is the RCRA section pertinent

to hazardous waste. The Staff Judge Advocate maintains

the most current versions of each of these regulations.

Specific RCRA requirements are discussed in the

following chapters. Failure to comply can potentially

result in criminal and civil penalties. Therefore,

knowledge of all hazardous waste requirements is crucial

to successful hazardous waste management.

2.3. Other Applicable Federal Laws and Regulations.

Although RCRA is the primary regulation guiding Air

Force hazardous waste management practices, other

legislation and regulations impact hazardous waste

management (see table 2.2). The impact of these laws on

an installation varies depending on the types of waste

produced, as well as the media (land, water, or air) into

 which the wastes can be released.

2.3.1. Comprehensive Environmental Response,

Compensation, and Liability Act of 1980 (CERCLA).

CERCLA regulates all hazardous substances; it was

established in 1980 to clean up inactive, abandoned sites

and enact emergency response procedures for hazardous

substance spills.

2.3.2. Federal Facility Compliance Act (FFCA). The

most recent RCRA amendment, the FFCA, extends the

waiver of the Federal Government’s sovereign immunity

relative to the provisions of RCRA Subtitle C. FFCA

establishes requirements for Federal facilities to comply

with all Federal, state, interstate, and local solid waste

regulations respecting hazardous waste disposal and

management in the same manner as private facilities. It

allows state and Federal agencies to assess Federal

facilities with fines for RCRA violations. Additionally,

FFCA requires that each permitted treatment, storage, and

disposal facility (TSDF) operated by the Federal

government receive an annual compliance inspection by

EPA.

2.4. DoD Directives and Air Force Policies. The

following DoD directives establish hazardous waste

requirements: DoD 4160.21-M, Defense Reutilization and

Marketing Manual, March 1990 with change 1; DoDD

5100.50, Protection and Enhancement of Environmental

Quality, May 24, 1973 with changes 1 and 2; and DoDD

6050.8, Storage and Disposal of Non-DoD-Owned

Hazardous or Toxic Materials on DoD Installations,

February 27, 1986. Air Force requirements include AFPD

32-70, Environmental Quality; AFI 32-7042, Solid and

Hazardous Waste Compliance; AFI 32-7045,

Environmental Compliance Assessment and Management

Program; AFI 32-7001 Environmental Budgeting; AFI

32-7080, Pollution Prevention Program; AFI 32-4002,

Hazardous Materials Emergency Planning and Response

Compliance; and AFI 48-119, Medical Service

Environmental Quality Programs. Another related

publication is DRMS-M 6050.1, Environmental

Compliance for the DRMS Hazardous Property Program.
AFPAM 32-7043 1 November 1995 7

Table 2.1. Overview of RCRA.

RCRA

SUBTITLE

Section

Number

SUBJECT 40 CFR Part

A

1004

GENERAL PROVISIONS

Definition 260

B OFFICE OF SOLID WASTE MANAGEMENT

C

3001

3002

3003

3004

3005

3006

3007

3014

3017

3020

HAZARDOUS WASTE MANAGEMENT

Identification & Listing of Hazardous Waste

Generators of Hazardous Waste

Transporters of Hazardous Waste

Owners and Operators of TSDF

Permits for TSDF

Authorized State Programs

Inspections

Regulation of Used Oil

Export of Hazardous Waste

Hazardous Waste Injection

261

262

263

264-268

270 and 124

271

260

279

262

267

D STATE OR REGIONAL SOLID WASTE PLANS

E DUTIES OF SECRETARY OF COMMERCE IN RESOURCE RECOVERY

F FEDERAL RESPONSIBILITIES

G MISCELLANEOUS PROVISIONS

H RESEARCH DEVELOPMENT, DEMONSTRATIONS AND INFORMATION

I UNDERGROUND STORAGE TANKS (UST)

J MEDICAL WASTE

2.5. State Regulations. States may be authorized by the

EPA to implement the RCRA program. To be approved,

the state program must meet conditions of consistency,

enforceability, and public hearing requirements. A state

may implement additional requirements, which must be at

least as stringent as Federal requirements and can be more

stringent.

2.6. Local Regulations. Local governments can also

implement regulations impacting hazardous waste

management. Each installation must ensure all applicable

local requirements are identified and followed.

2.7. Roles and Responsibilities. The responsibilities

associated with hazardous waste management extend to

many personnel and activities (including all contractors)

on an installation. This section outlines major roles and

responsibilities.

2.7.1. Installation Commander. The Installation

Commander is ultimately responsible for hazardous waste

management and compliance. Responsibilities include

ensuring the following activities are met:

2.7.1.1. Hazardous waste management is given a top

priority and is emphasized to all base personnel.

2.7.1.2. All hazardous waste permits and manifests are

signed.

2.7.1.3. Enforcement actions (if received) are quickly

attended to.

2.7.1.4. A hazardous waste management plan is created

and in place.

2.7.1.5. All personnel involved with hazardous waste

have the required training and receive refresher training.

2.7.2. Environmental Protection Committee. The

environmental protection committee is the primary

vehicle available to the installation commander to oversee

compliance with hazardous waste disposal requirements.

The environmental protection committee reviews and

coordinates the hazardous waste management program.

2.7.3. Base Environmental Flight. The base

environmental flight, supervised by the environmental

manager, is the installation commander's organization for

ensuring the hazardous waste management process is in

compliance with all Federal, state, interstate, and local

environmental requirements. Responsibilities include:
8 AFPAM 32-7043 1 November 1995

Table 2.2. Federal Laws and Their Impact on Air Force Installations.

LAW

POTENTIAL IMPACTS TO

AIR FORCE INSTALLATIONS

Hazardous Materials Transportation Act (HMTA) Outlines requirements for the transportation of Hazardous

Waste.

Toxic Substances Control Act (TSCA) Regulates management of PCBs and other toxic wastes.

Occupational Safety and Health Act (OSHA) Regulates work safety, emergency response, clean up, and

training requirements.

Clean Air Act (CAA) Regulates air emissions from RCRA TSDFs and

incinerators.

Hazardous sludge from CAA-permitted scrubbers must

comply with RCRA if it is a listed or characteristic

hazardous waste.

Federal Facility Compliance Act (FFCA) Waives sovereign immunity for penalties under RCRA.

Allows EPA and the states to impose fines for noncompliance.

Emergency Planning and Community Right-to-Know Act (EPCRA) Outlines requirements for emergency planning, notification,

response, working with the local community, and reporting.

Pollution Prevention Act (PPA) Outlines principles guiding waste management practices.

Comprehensive Environmental Response, Compensation, and

Liability Act of 1980 (CERCLA)

Regulates cleanup of past wastes.

2.7.3.1. Acting as the liaison office for environmental

compliance issues with regulatory agencies;

2.7.3.2. Providing technical expertise with regard to

hazardous waste labeling, storage, disposal, and

recordkeeping;

2.7.3.3. Conducting required documentation training;

2.7.3.4. Completing land disposal restriction information

on the hazardous waste profile sheet and manifest;

2.7.3.5. Ensuring accurate hazardous waste weighing for

turn-in and disposal in the presence of an authorized DoD

representative;

2.7.3.6. Certifying DD Form 1348-1, DoD Single Line

Item Release/Receipt Document;

2.7.3.7. Identifying installation personnel authorized to

carry turn-in and disposal documents;

2.7.3.8. Completing and signing the hazardous waste

manifest when the designee of the installation

commander;

2.7.3.9. Overseeing proper programming and recordkeeping procedures (disposal funding and future

requirements including waste analysis);

2.7.3.10. Developing the installation hazardous waste

management plan;

2.7.3.11. Prepare and modify permits;

2.7.3.12. Maintaining all records in the WIMS-ES

hazardous waste module;

2.7.3.13. Maintaining a hazardous waste file which

contains as a minimum copies of hazardous waste profile

sheets, DD Forms 1348-1, manifests, M-15 report, waste

stream inventory, and hazardous waste management plan;

2.7.3.14. Prepare biennial and other applicable state

inventories;

2.7.3.15. Developing and submitting 5-year budget

request for facilities, personnel, training, waste disposal,

etc.; and

2.7.3.16. Ensuring proper disposal of all hazardous waste

from their installation.

2.7.4. Bioenvironmental Engineering Services.

Responsibilities include the following:

2.7.4.1. Completing the health related sections of the

hazardous waste profile sheet;

2.7.4.2. Evaluating industrial processes to properly

characterize installation waste streams;

2.7.4.3. Identifying analytical, training and equipment

requirements to the environmental flight for base funding

of all these requirements;

2.7.4.4. Developing hazardous waste analysis plans and

forwarding a copy to the environmental flight for

inclusion in the hazardous waste management plan;

2.7.4.5. Developing hazardous waste stream inventories;

2.7.4.6. Reviewing plans to build or modify facilities used

to treat, store, or dispose of hazardous waste, including all

proposals to establish or relocate accumulation points;

2.7.4.7. Performing technical reviews of locally

developed hazardous waste analysis contracts;

2.7.4.8. Collecting, preparing, and arranging for the

transport of samples for waste stream analysis;

2.7.4.9. Maintaining a copy of each hazardous waste

profile sheet in the generating activities' shop folder;

2.7.4.10. Including in annual workplace evaluations an

evaluation of compliance with RCRA and waste

minimization activities; and

2.7.4.11. Conducting health risk assessments at waste

accumulation sites and during spill response.
AFPAM 32-7043 1 November 1995 9

2.7.5. Generating Activity. Responsibilities include the

following:

2.7.5.1. Ensuring all wastes are properly characterized

when newly generated and when waste streams have

changed;

2.7.5.2. Managing all initial accumulation points in

accordance with the base hazardous waste management

plan;

2.7.5.3. Notifying the environmental flight of all changes

in hazardous waste activities including waste stream

process modifications, relocation of initial accumulations

points, and names of newly assigned shop monitors;

2.7.5.4. Completing all required disposal documents

(hazardous waste profile sheet, AF Form 2005,

Issue/Turn-In Request, and DD Form 1348-1);

2.7.5.5. Maintaining a hazardous waste file, which

contains as a minimum copies of each hazardous waste

profile sheet , waste analyses results, AF Form 2005, DD

Form 1348-1s, and manifests;

2.7.5.6. Ensuring hazardous waste is properly

characterized, segregated, marked, labeled, weighed,

stored, packaged, and transferred for disposal; and

2.7.5.7. Consulting with the environmental manager,

bioenvironmental engineering services, and HAZMAT

Planning Team before any hazardous waste disposal

process or activity is modified, or a new process or activity

is planned.

2.7.6. Base Transportation Officer. Advises on proper

shipping containers and transportation requirements,

including the hazardous waste manifest. Works with

munitions personnel to arrange shipment of hazardous

waste munitions. If required by state regulations, provides

transportation vehicles and drivers that possess a current

commercial drivers license (CDL) to transfer hazardous

waste to the DRMO.

2.7.7. Defense Reutilization and Marketing Office.

The Defense Reutilization and Marketing Service,

through their DRMOs, is the DoD hazardous waste

disposal agent. Responsibilities include the following:

2.7.7.1. Providing a hazardous waste disposal service to

the installation;

2.7.7.2. Providing information on hazardous waste profile

sheet, Defense Industrial Supply Center, EPA land

disposal requirements;

2.7.7.3. Completing and signing the hazardous waste

manifest when the designee of the installation

commander;

2.7.7.4. Providing a copy of "closed" hazardous waste

manifests to the environmental manager once received

from the TSDF;

2.7.7.5. Recordkeeping of all hazardous waste profile sheets

and associated reference numbers, and maintaining copies of

manifests for three years;

2.7.7.6. Adhering to generating activity responsibilities

regarding any waste streams it generates; and

2.7.7.7. Adhering to all tenant responsibilities.

2.7.8. HAZMAT Planning and Response Teams.

Ensure adequate preparation and necessary resources for

responding to hazardous waste releases (see AFPAM 32-

4013, Hazardous Materials Emergency Planning and

Response Guide for further guidance).

2.7.9. Base Supply. When required, establishes a single

point of contact for controlling required hazardous waste

supply actions and for processing transactions. Processes

paperwork transactions, and maintains computer records

for hazardous waste disposal actions. Transactions are

processed to record turn-in actions and produce disposal

documentation when disposal is required and authorized

by the environmental manager. Base supply, however,

does not accept physical custody of hazardous waste.

Prepares a Disposal Turn-In Document using DD Form

1348-1, DoD Single Line Item Release/Receipt Document.

2.7.9.1. The current capability for the standard base

supply system to process hazardous waste transactions

remains available for those installations desiring to use it.

However, where installations have developed alternate

procedures and systems for hazardous waste disposal, the

installation commander has the option to use a local

system. This does not transfer responsibilities identified

in Air Force supply policies and procedures from base

supply to civil engineering or any other organization. It

only makes the use of standard base supply system

hazardous waste processing procedures optional and gives

the installation commander the flexibility to implement

one program, one manager, one stop processing for

hazardous waste using any organization or system that

fulfills DoD requirements for hazardous waste turn-in and

disposal. Prior to implementing any change from

standard base supply system hazardous waste processing,

local operating instructions must be developed and

coordinated with all base level activities having Air Force

supply responsibilities.

2.7.10. Contracting. Ensures timely and effective

contracting support is provided to environmental

managers’ to accomplish hazardous waste management.

This includes using applicable provisions of the Federal

Acquisition Regulation (FAR) and environmental policies

and procedures.

2.7.11. Accounting and Finance Officer. Commits

funds using the AF Form 616, Fund Cite Authorization

(FCA) obligates funds when DD Form 1348-1 are

received, processes MILSBILLS billings, and requests

adjustments based on the environmental manager's

monthly M-15 report. For overseas locations, the Military

Interdepartmental Purchase Request is used instead of the

interfund billing system.

2.7.12. Air Force Installation Tenants. Complies with

the installation's hazardous waste management program.

When a tenant is in non-compliance with hazardous waste

laws, the installation commander has the authority to take

whatever action is necessary to require tenants (and all

contractors) to comply. Tenant responsibilities include

the following:
10 AFPAM 32-7043 1 November 1995

2.7.12.1. Complying with applicable portions of the

hazardous waste management plan and ensuring internal

operating procedures are consistent;

2.7.12.2. Providing input for their portions of the

hazardous waste management plan;

2.7.12.3. Assuring necessary permits cover their off-base

activities,

2.7.12.4. Conducting their activities in accordance with

the installation's permit requirements; and

2.7.12.5. Submitting reports required by the installation's

hazardous waste management plan within time frames

established.

____________________________________________________________________________________________________

Chapter 3

HAZARDOUS WASTE GENERATION

 (CHARACTERIZATION)

GENERATION

PHASE

STORAGE

PHASE

DISPOSAL

PHASE

CHARACTERIZATION STEP

CONTAINER/

TANK MNGT

STEP

GENERATOR

CLASSIFICATION STEP

ACCUMULATION MNGT

STEP

TURN-IN

STEP

TRANSPORT

STEP

DISPOSAL STEP

3.1. Overview. A waste is a solid, liquid, or gaseous

substance that no longer has a use for its intended

purpose. EPA defines waste as hazardous if it has certain

properties that could pose dangers to human health and

the environment after it is discarded. The hazardous

waste life-cycle begins with the Generation Phase, which

includes generating waste, determining if the waste

generated is hazardous, and characterizing hazardous

waste. Hazardous waste generation is the physical activity

creating the waste, while hazardous waste

characterization defines and identifies waste as hazardous.

3.1.1. Generation. Generation of hazardous waste

results from a variety of processes and procedures. The

unit or group involved in the hazardous waste generation

is referred to as the generating activity. Examples of Air

Force generating activities include corrosion control,

transportation, vehicle maintenance, auto hobby activities,

explosive ordnance disposal, non-destructive inspection,

dry cleaning, reproduction and printing, aircraft

maintenance, base hospital activities, photo lab activities,

pest management, materials and analytical lab activities,

and plating. Hazardous waste generated by these

activities include spent solvents, paint thinners,

contaminated paint removers, wiping rags, expended

photo developing solutions, waste petroleum products,

battery acid, dry-cleaning solvents, contaminated inks,

cleaning fluids, pesticide residues, expended

electroplating solutions, and hazardous materials which

can no longer be used. Although there are several

generating activities on an installation, the installation as

a whole is considered a single generator for regulatory

purposes.
AFPAM 32-7043 1 November 1995 11
12 AFPAM 32-7043 1 November 1995

3.1.2. Is it Regulated? Most solid waste that is generated

is not hazardous. To determine whether a specific

substance being discarded is regulated as hazardous by

RCRA, three questions must be answered: is the

substance a solid waste?; is it a hazardous waste?; and is it

exempted by RCRA regulation?

3.1.3. Characterization. Once a waste is determined

hazardous, it must be listed or characterized. Each

generating activity characterizes their hazardous waste

following the Air Force process of identifying the type of

hazardous waste, describing the hazardous waste, and

quantifying the amount generated. A listed hazardous

waste is a waste already determined by the EPA to be

hazardous and is specifically listed as such.

3.1.4. Appendix I to 40 CFR Part 260. Appendix I to

40 CFR Part 260, Overview of Subtitle C Regulations,

Figures 1 through 4, should be used in conjunction with

this chapter as you review the characterization substeps.

3.2. Hazardous Waste Regulatory Process. Each

generating activity must determine if any substance,

which is to be discarded, is actually a hazardous waste

subject to RCRA Subtitle C rules. The regulatory process

(see figure 3.1) has three criteria which establishes a

hazardous waste so regulated.

3.2.1. Is Substance a Solid Waste? The first step is to

determine if the substance is classified as a solid waste.

Solid wastes, by definition, are not strictly solid; solid

wastes include liquids and containerized gases. The

following criteria define a substance as a solid waste:

• The substance is abandoned by being disposed of,

burned, or incinerated.

• The substance is accumulated, stored, or treated (but

not recycled) before or in lieu of being disposed of,

burned, or incinerated.

• The substance is a secondary material and is recycled;

or accumulated, stored, or treated before recycling.

• The substance is inherently waste-like and is

recycled.

3.2.1.1. Some substances are excluded from classification

as a solid waste. If the generating activity believes a

waste falls under one of the following exclusions (the list

is not all inclusive), they should review the exclusions

with the environmental manager to make the proper

determination:

3.2.1.1.1. Substances that are being recycled by being

used, reused, or returned to the original process without

first being reclaimed (such as “off-spec” jet fuel); [40

CFR § 261.2]

3.2.1.1.2. Domestic sewage; [40 CFR § 261.4]

3.2.1.1.3. Industrial wastewater discharges covered by the

Clean Water Act; [40 CFR § 261.4]

3.2.1.1.4. Irrigation return flows; [40 CFR § 261.4]

3.2.1.1.5. Substances reclaimed and returned to the

generating process by means of a totally enclosed

reclamation process and means of conveyance; and [40

CFR § 261.4]

3.2.1.1.6. Radioactive substances controlled by the

Atomic Energy Act. [40 CFR § 261.4]

3.2.2. Is Substance Hazardous? The next step is to

determine if the solid waste is hazardous. EPA considers

a waste to be hazardous if it possesses certain

characteristics (ignitable, corrosive, reactive, or toxic) or

if it is on a list of specific wastes determined by the EPA

to be hazardous. A mixture of a non-hazardous waste and

a characteristic hazardous waste or a listed hazardous

waste is considered a hazardous waste until proven

otherwise. Table 3.8 provides a matrix of the typical

hazardous wastes generated at Air Force installations. [40

CFR § 261.3]

3.2.2.1. Characteristic wastes meet one or more of the

following descriptions:

3.2.2.1.1. Ignitable--a liquid that has a flash point less

than 140° F; a non-liquid capable, under normal ambient

conditions, of causing fire through friction, absorption of

moisture, or spontaneous chemical changes and, when

ignited, burns so vigorously and persistently that it creates

a hazard; a compressed gas defined as ignitable by DOT

regulation (49 CFR § 173.300); or an oxidizer as defined

by DOT regulation (49 CFR § 173.151). Ignitable wastes

are identified by the EPA hazardous waste number D001.

[40 CFR § 261.21]

3.2.2.1.2. Corrosive--aqueous solutions having a pH

greater than or equal to 12.5 (strong base), or less than or

equal to 2 (strong acid); or a liquid which corrodes steel

faster than 0.25 inch per year at 130° F. Corrosive wastes

are identified by the EPA hazardous waste number D002.

[40 CFR § 261.22]

3.2.2.1.3. Reactive--materials that react violently with

water; are normally unstable and readily undergo violent

changes without detonating; form potentially explosive

mixtures with water; when mixed with water, generate

toxic gases, vapors or fumes in a quantity sufficient to

harm humans or the environment; contain cyanide or

sulfide which, when exposed to conditions of pH between

2 and 12.5, generates toxic gases, vapors, or fumes in a

quantity sufficient to harm humans or the environment; is

capable of detonation or an explosive reaction if subjected

to a strong initiating source or if heated under

confinement; capable of detonation or explosive

decomposition or reaction at normal ambient conditions;

or classified as a DOT forbidden explosive, a Class A

explosive (1.1 or 1.2 explosives), or Class B explosive (1.2

or 1.3 explosives). Reactive wastes are identified by the

EPA hazardous waste number D003. [40 CFR § 261.23]

3.2.2.1.4. Toxic--materials that are harmful or fatal when

swallowed or comes in contact with the skin. When

disposed of on land, contaminated liquid might drain

(leach) from the waste and pollute groundwater. Toxicity

is determined through the Toxicity Characteristic

Leaching Procedure (TCLP), a test contained in Test
AFPAM 32-7043 1 November 1995 13

Methods for Evaluating Waste, Physical/Chemical

Methods, EPA Publication SW-846. The test determines

if the hazardous waste contains certain constituents

(certain metals, pesticides, and organic chemicals) at

concentrations listed in Table 1 of 40 CFR § 261.24.

Toxic wastes are identified by a range of EPA hazardous

waste numbers, D004 through D043. [40 CFR § 260.11

and 261.24]

3.2.2.2. Listed wastes include wastes determined by the

EPA to be hazardous and placed on selected lists

published in the CFR. There are three groups of Listed

Wastes:

3.2.2.2.1. Non-specific Source Wastes--wastes generated

by generic activities, such as degreasing and surface

preparation. Known as F-list wastes, non-specific source

listed wastes include certain spent solvents, plating

wastes, metal treating wastes, and certain chlorinated

organic compounds. [40 CFR § 261.31]

3.2.2.2.2. Specific Source Wastes--generated by specific

sources or industries. Known as K-list wastes, they

include organic chemicals, inorganic pigments, waste

from petroleum refining, veterinary, pharmaceutical,

cooking industries, and explosives. The Air Force does

not typically generate any K-list wastes. [40 CFR §

261.32]

3.2.2.2.3. Discarded Commercial Wastes--wastes that

contain discarded commercial products, off-specification

commercial chemical products, container residues, or spill

residues, and have a sole active ingredient consisting of

the generic chemicals listed on the P-list or U-list. These

waste codes refer to specific chemical substances that are

the product of a specific manufacturing or formulation

process. Discarded commercial wastes include

chloroform, creosote, dated drugs, and reagents. [40 CFR

§ 261.33]

3.2.2.3. Acute Hazardous Waste. Within the listed

wastes, there are certain wastes which are acutely toxic in

nature and are classified as acute hazardous waste. These

hazardous wastes have been found to be fatal to humans in

low doses or capable of significantly contributing to an

increase in serious irreversible or incapacitating reversible

illnesses. Requirements for acute wastes are more

stringent than those for hazardous waste. Acute

hazardous waste includes all P-list wastes and some F-list

wastes. [40 CFR § 261.31, 261.32, and 261.33]

3.2.2.4. Hazardous Waste Mixtures. Non-hazardous

solid waste mixed with a listed waste is still considered a

hazardous waste. However, if the waste is listed solely

because it exhibits one of the four characteristics of a

hazardous waste, and the mixture no longer exhibits any

of those characteristics, the mixture is not considered

hazardous. Comment: Mixing hazardous waste with

non-hazardous waste to render it non-hazardous is a

treatment method requiring a permit. [40 CFR § 261.3]

3.2.2.5. Excluded Wastes. Some wastes are excluded

from classification as a hazardous waste. If a generating

activity believes that a waste falls under one of the

following exclusions (the list is not all inclusive), they

should review the exclusions with the environmental

manager to make the proper determination:

3.2.2.5.1. Mixture of wastewater and certain hazardous

wastes the discharge of which is covered by the Clean

Water Act; [40 CFR § 261.3]

3.2.2.5.2. Household waste (from residential sources

only); [40 CFR § 261.4]

3.2.2.5.3. Agricultural wastes returned to soils as

fertilizers; [40 CFR § 261.4]

3.2.2.5.4. Specific ash and slag waste from coal or fossil

fuel combustion; [40 CFR § 261.4]

3.2.2.5.5. Specific petroleum-contaminated media and

debris from corrective actions for underground tanks (see

40 CFR Part 268) that fail EPA’s Toxicity Characteristic

test (hazardous waste codes D018 through D043); [40

CFR § 261.4]

3.2.2.5.6. Discarded arsenic-treated wood or wood

products which fail the test for Toxicity Characteristic for

hazardous waste codes D004 through D017; [40 CFR §

261.4]

3.2.2.5.7. Non-terne plated used oil filters that are not

mixed with listed hazardous waste if the filters have been

gravity hot-drained; and [40 CFR § 261.4]

3.2.2.5.8. Used chlorofluorocarbon refrigerants from

certain totally enclosed devices provided the refrigerant is

reclaimed for further use. [40 CFR § 261.4]

3.2.3. Is Substance Exempted? Finally, there are many

substances, which although hazardous, are exempt under

a variety of criteria. If a generating activity believes that a

waste falls under one of the following general exemptions

(the list is not all inclusive), they should review the

following RCRA exemptions with the environmental

manager to make the proper determination:

3.2.3.1. Sample collected for testing to determine

characteristics or composition, as long as the sample is in

transport to or from the laboratory, or being stored prior to

transport or at the laboratory (once the sample is returned,

it is no longer exempted); [40 CFR § 261.4]

3.2.3.2. Treatability study samples not exceeding 10,000

kg in quantity; [40 CFR § 261.4]

3.2.3.3. Waste generated by conditionally exempt small

quantity generators; [40 CFR § 261.5]

3.2.3.4. Certain recyclable substances (such as batteries

and scrap metal); [40 CFR § 261.6]

3.2.3.5. Residues of hazardous waste in empty containers

or inner liners, provided the waste is not a listed acute

hazardous waste; and [40 CFR § 261.7]

3.2.3.6. PCB wastes regulated under the Toxic

Substances Control Act. [40 CFR § 261.8]

3.3. Air Force Characterization Process. The Air

Force process to characterize waste incorporates the

regulatory process for determining if a substance is

regulated as a hazardous waste during the identification
14 AFPAM 32-7043 1 November 1995

substep and for documenting that fact in the description

substep.

3.4. Identification Substep. Once the substance is

determined a hazardous waste, it must be properly

identified as a waste stream on the installation. A waste

stream is identified as a process that generates a specific

solid waste and is assigned a unique identification number

at the installation. (DOT refers to EPA hazardous waste

numbers as "waste streams"; not to be confused with the

Air Force term for waste streams.) The components of the

waste streams are identified either by testing in

accordance with methods specified by EPA in the

appendices to 40 CFR Part 261, or by applying knowledge

of the hazardous characteristics of the waste in light of

materials and processes used. Waste sampling and

chemical analysis are required by EPA or the state if the

constituents of the waste stream are unknown, if

hazardous waste characteristics are unknown, or if the

waste is subject to land disposal restrictions.

3.4.1. Waste Analysis Plans. The waste analysis plan

is the primary document used to identify waste streams

that are regulated as hazardous waste (see paragraph

3.6.1., Developing the Hazardous Waste Stream

Inventory). Written by bioenvironmental engineering

services, the waste analysis plan describes the

installation's procedures for identifying all potential

hazardous waste streams and determining which

hazardous waste streams require detailed hazardous waste

determination. Each installation's waste analysis plan is

incorporated into the hazardous waste management plan.

A sample waste analysis plan is included in Attachment 2

- Sample hazardous waste management plan. The waste

analysis plan includes the following:

• A list of all wastes generated at the installation which

require evaluation and analysis;

• Test methods used (in accordance with the EPA

analytical methods published in Test Methods for

Evaluating Solid Waste, Physical/Chemical Methods,

EPA publication SW-846);

• Hazardous waste sampling methods (methods and

personal protective and sample collection equipment

used for sampling waste materials vary with the form

and composition of the waste materials to be sampled;

samples are collected using the protocols specified in

40 CFR Part 261 Appendix I);

• Sample analysis locations and frequency (describing

how many samples will be taken from each waste

stream, as well as describing the sampling strategy;

individual samples should be representative of the

total waste stream being analyzed);

• A description of the analytical methods used;

• Sample documentation;

• Sample quality assurance/quality control procedures

(following the procedures found in SW-846 to assure

reliable analytical data which is defensible if

questions are raised about the data used to complete

hazardous waste determinations; 40 CFR Part 261

Appendix III lists all of the Test Methods found in

SW-846); and

• Sample request procedures.

3.4.1.1. The waste analysis plan should also include a

procedure for periodic reevaluation of each waste stream.

All waste streams must be evaluated at the following

frequencies:

3.4.1.1.1. When the process or operation generating the

hazardous waste has changed;

3.4.1.1.2. Annually following the initial characterization

for each high volume hazardous waste stream (those that

generate four or more 55-gallon drums of waste per year);

and

3.4.1.1.3. At least every three years for low volume

hazardous waste streams (those that generate three or

fewer 55-gallon drums per year).

3.4.1.2. The waste analysis plan is evaluated and

reviewed annually to ensure the most up-to-date

procedures are conducted. The plan is also reviewed and

revised at other times:

3.4.1.2.1. The sample frequency changes due to changes

in the annual volume of an installation’s hazardous waste

stream;

3.4.1.2.2. Analytical parameters change due to changes

in the processes generating hazardous waste;

3.4.1.2.3. EPA hazardous waste numbers and/or DOT

identification numbers change due to regulatory revisions;

and

3.4.1.2.4. Disposal methods change due to revisions to

land disposal restrictions or changes in disposal contracts.

3.4.1.3. The waste analysis plan should contain

procedures for documenting waste streams that are subject

to the solid or hazardous waste exclusions or exemptions.

For example, “off-spec” JP-4 used in fire training, used

batteries returned to the battery manufacturer, and scrap

metal which is being recycled do not have to be managed

as hazardous wastes, but their disposition must be

documented. The documentation is a one-time notice in

the generating activity's, environmental flight's, and

bioenvironmental engineering service's files identifying

the following:

3.4.1.3.1. Amount and type of waste generated (e.g., 5500

lbs/yr “off-spec” JP-4);

3.4.1.3.2. Subsequent exclusion or exemption (e.g.,

excluded under 261.2(e)(1)(ii)); and

3.4.1.3.3. The disposition of the waste (e.g., used in oninstallation fire training exercise).

This documentation must be maintained on site for at

least five years from the date the waste was last sent to

on-site or off-site recycling treatment, storage, or disposal.

[40 CFR § 268.7(a)(6) and (7)]

3.4.2. Used Oil and Oil Filters. Used oil requirements

are identified in 40 CFR Part 279. Used oil will only be
AFPAM 32-7043 1 November 1995 15

disposed of as hazardous waste when it cannot be recycled

or burned for its energy value. Used oil that is recycled by

refining it a second time or processing it to produce a

usable product or by burning it for energy recovery is not

subject to RCRA waste determination requirements even

if the used oil exhibits a hazardous waste characteristic.

Waste oil to be disposed of must be evaluated to determine

whether it exhibits a hazardous waste characteristic or

contains a listed hazardous waste. This includes oil

filters, oil-soaked absorbent materials, or oily rags which

are not recycled.

3.4.2.1. Used oil that is mixed with hazardous waste or

contains more than 1000 ppm total halogens is presumed

to be hazardous waste because it has been mixed with a

listed, halogenated hazardous waste and is subject to all

applicable hazardous waste management requirements

when it is burned for energy recovery. Transporters are

required to analyze each shipment of waste oil for halogen

concentrations. [40 CFR § 279.10(b) and § 279.44]

3.4.2.2. Used oil that is to be burned for energy recovery

should be analyzed to determine if it meets the

specifications presented in table 3.1. If the oil does not

meet the requirements it is considered off-specification

and is subject to specific hazardous waste regulations.

Bioenvironmental engineering services should contact the

DRMO and review waste oil recycling or disposal

contracts to determine who will analyze waste oil to

determine its regulatory status. [40 CFR § 279.11]

Table 3.1. RCRA Specifications for Used Oil Burned for Energy Recovery.

Constituent/Property Allowable Level

Arsenic 5 ppm maximum

Cadmium 2 ppm maximum

Chromium 10 ppm maximum

Lead 100 ppm maximum

Total Halogens 4,000 ppm maximum

Flash Point 100°F minimum

3.4.2.3. According to EPA regulations on the

management of polychlorinated biphenyls (40 CFR 761),

all used oil burned for energy recovery is presumed to

contain quantifiable levels (2 ppm or greater) of PCBs

unless the marketer obtains analyses or other information

that the used oil fuel does not contain PCBs.

3.4.2.4. Oil filters must be properly drained following the

method described in the May 20, 1992 Federal Register

(57 FR 21524). If an oil filter is picked up by hand and

used oil immediately drips or runs from the filter, the

filter is not considered drained and must be subjected to a

determination of whether it exhibits any characteristic of

hazardous waste.

3.4.3. DoD Ammunition and Explosive Safety

Standards. All conventional explosive ordnance,

whether it remains useable or has been designated as

waste, will be managed in accordance with DoD 6055.9-

STD, DoD Ammunition and Explosives Safety Standards,

30 October 1992. Conventional explosive ordnance

operations involving hazardous waste must be managed in

accordance with the applicable RCRA requirements. If

any RCRA requirements conflict with the DoD

Ammunition and Explosives Safety Standards, the

responsible individual, working with the environmental

manager, must notify the appropriate regulatory agency

and, if necessary, expeditiously elevate any disputes

through the chain of command for resolution. In

resolving such conflicts, prevention of injury and

protection of life will be the primary concern of the Air

Force decision maker. All conventional explosive

ordnance operations, whether or not subject to RCRA,

must be performed in a responsible manner to prevent

undue damage to the environment.

3.4.3.1. All generation, transportation, storage, treatment,

or disposal of conventional explosive ordnance designated

as hazardous waste is subject to RCRA requirements.

Conventional explosive ordnance will be identified as

hazardous waste when: an authorized official (person

designated in writing) records in writing a determination

that the conventional explosive ordnance will be

discarded; and custodians of the conventional explosive

ordnance receive this written determination that the

conventional explosive ordnance is to be discarded and,

therefore, subject to RCRA regulation. (NOTE: Prior

written authorization is not required if safety or other

considerations (e.g., an emergency response conducted by

Explosive Ordnance Disposal (EOD) unit or a response to

mitigate an imminent hazard) preclude obtaining prior

written authorization.)

3.4.3.2. The authorized official must take into account

the facts and circumstances applicable to each situation in

making a determination to discard. The following

guidelines should be used in making this determination:

3.4.3.2.1. A determination to discard excess conventional

explosive material that is safe and stable in normal

logistical environments by military standards may be
16 AFPAM 32-7043 1 November 1995

made only after all efforts have been exhausted to reuse,

recycle, recover, or sell such material.

3.4.3.2.2. A determination to discard conventional

explosive ordnance that may be unstable or unsafe to store

or transport should be made by an authorized official after

conducting appropriate testing or inspection, if conditions

allow, or if it is readily apparent that there is no

reasonable alternative for discarding the material.

3.4.3.2.3. Generally, conventional explosive ordnance

manufacture, assembly, testing, training, intended use, or

range management do not constitute hazardous waste

management. Some wastes generated by these operations,

however, may be subject to RCRA.

3.4.3.3. At all times, accounting classification of

conventional explosive ordnance must accurately reflect

its actual disposition and condition. Prior to making the

determination to discard, the conventional explosive

ordnance material will normally be placed in the Air

Force equivalent of the Resource Recovery and

Disposition Account (RRDA) thereby removing them

from the active inventory and beginning the evaluation

process. When a decision to discard has been made, the

conventional explosive ordnance material will be

designated a hazardous waste. Upon the decision to

discard, it must be properly transferred to the Air Force

equivalent of the Hazardous Waste Account (BHW) in

order to ensure proper management under RCRA. If the

decision is made to discard the conventional explosive

ordnance item from the active inventory without further

evaluation, the item will be removed from the active

inventory and will be placed directly in the BHW account,

bypassing the RRDA account.

3.4.3.4. Conventional explosive ordnance that has

previously been designated as waste, but for which a

legitimate use subsequently is identified, may be redesignated as non-waste, not subject to RCRA. An

authorized official will record this determination in

writing. If this determination cannot be made, 40 CFR

261.3(c)(1) states that a hazardous waste will remain a

hazardous waste unless and unti the waste ceases to

exhibit a characteristic of a hazardous waste as described

under 40 CFR Part 261, Subpart C; or it has been

specifically excluded by regulation (i.e., delisted).

3.4.4. Collecting and Analyzing Waste Samples. An

essential part of any sampling and analytical process is

ensuring the integrity of the sample from collection to

data reporting. The possession and handling of samples

should be traceable from collection through analysis and

final disposition. The documentation of the sample

history is called chain-of-custody and is needed if there is

any possibility that analytical data or conclusions based on

the data will be used in litigation. The parts of the

chain-of-custody process include sample labels, sample

seals, field logbooks, chain-of-custody records, laboratory

sample request sheets, and waste analysis reports.

Specific procedures for collecting and analyzing waste

streams is described in the waste analysis plan, chapter 4,

of the sample hazardous waste management plan,

attachment 2.

3.4.4.1. Sample labels are placed on containers prior to

sampling and filled out at sample collection. Necessary

information includes sample number, name of collector,

date and time of collection, place of collection, and any

important remarks. Sample seals are used to detect

unauthorized tampering with samples; the seal is attached

so it is necessary to break the seal to open the sample

container. Bioenvironmental engineering services can

provide more information on sample collection labels and

seals.

3.4.4.2. All information pertinent to field surveys and

sampling should be recorded in a field logbook. The

logbook should record the following information:

3.4.4.2.1. Location of the sampling point;

3.4.4.2.2. Name and address of the installation and

activity that generated the waste;

3.4.4.2.3. Type of process(es) producing the waste;

3.4.4.2.4. Physical form of waste, such as sludge, liquid,

solid, etc;

3.4.4.2.5. Suspected waste composition;

3.4.4.2.6. Waste stream number;

3.4.4.2.7. Number and volume of sample taken;

3.4.4.2.8. Purpose of sampling;

3.4.4.2.9. Description of sampling point and sampling

methodology;

3.4.4.2.10. Date and time of collection;

3.4.4.2.11. Sample collector's identification number;

3.4.4.2.12. Lab that will analyze the sample and method

of shipment;

3.4.4.2.13. References, such as maps and photographs of

the sampling site;

3.4.4.2.14. Field observations;

3.4.4.2.15. Any field measurements made, such as pH or

flammability; and

3.4.4.2.16. Signature of personnel responsible for logbook

entries.

3.4.4.3. A chain-of-custody record should also be filled

out and accompany every sample. This record contains

the following information:

3.4.4.3.1. The sample number;

3.4.4.3.2. Signature of collector;

3.4.4.3.3. Date and time of collection;

3.4.4.3.4. Place and address of collection;

3.4.4.3.5. Waste type;

3.4.4.3.6. Signature of persons involved in the chain of

custody; and

3.4.4.3.7. Inclusive dates of possession.

3.4.4.4. A sample analysis request sheet should

accompany the sample to the laboratory. The field portion

of the form is completed by the person collecting the

sample and should include pertinent information noted in

the logbook. The laboratory portion of the form is then

completed by laboratory personnel and includes the name
AFPAM 32-7043 1 November 1995 17

of the person receiving the sample, laboratory sample

number, date and time of sample receipt, sample

allocation, and analysis performed.

3.4.4.5. Samples collected for the sole purpose of

determining characteristics and composition do not have

to be managed as hazardous waste while the sample is

shipped to a laboratory, temporarily stored by a laboratory,

or returned to the installation.

3.4.4.6. Sample shipments must comply with all

applicable DOT classification, description, packaging,

marking, labeling, and other transportation requirements

for hazardous materials. A sample may be excluded

under DOT requirements, but the EPA requires the

following information accompany every sample shipment:

3.4.4.6.1. Sample collector's name, mailing address, and

telephone number;

3.4.4.6.2. Laboratory's name, mailing address, and

telephone number;

3.4.4.6.3. Quantity of the sample;

3.4.4.6.4. Date of the shipment; and

3.4.4.6.5. Description of the sample.

3.5. Description Substep. The next substep in the

hazardous waste characterization process is description.

This part of characterization is describing all hazardous

waste streams when they are generated on the installation,

as required by the waste analysis plan. The information

obtained through waste identification in accordance with

the installation’s waste analysis plan is used to complete

the hazardous waste profile sheet on each hazardous waste

stream.

3.5.1. Hazardous Waste Profile Sheet. DRMS Form

1930, Hazardous Waste Profile Sheet, is used for

describing hazardous waste streams. The hazardous waste

profile sheet is used for all disposal actions, whether or

not the DRMO is the disposal agent. The hazardous

waste profile sheet can be obtained from the local DRMO.

If the local DRMO is not the disposal agent, the

hazardous waste profile sheet can be obtained from the

base environmental function.

3.5.1.1. DRMO uses the information contained on the

hazardous waste profile sheet to alert disposal contractors

of possible disposal restrictions. DRMO assigns an initial

reference number to each hazardous waste profile sheet.

Subsequent turn-ins of the same waste stream do not

require that the hazardous waste profile sheet accompany

the waste. Instead, the generating activity simply enters

the reference number in the “Remarks” section (block

AA) of the disposal turn-in document, another document

submitted when waste is turned in. The hazardous waste

profile sheet filed at DRMO becomes part of the operating

record when DRMO is operating a permitted storage

facility. All hazardous waste profile sheets must be

updated by 1 December each year to DRMO and when the

waste stream changes.

3.5.1.2. Analytical results are used to complete the

hazardous waste profile sheet. All analytical results from

waste evaluation activities should be attached to the

hazardous waste profile sheet and accompany all disposal

documents provided to the DRMO.

3.5.2. Completion of the Hazardous Waste Profile

Sheet. The hazardous waste profile sheet consists of three

parts (see figures 3.2 and 3.3, and table 3.2). The waste

generating activity, with the assistance of the base

functions identified below, has the responsibility of

completing Parts I and II of the hazardous waste profile

sheet. The DRMO completes Part III of the hazardous

waste profile sheet. Initial sampling may be required in

order to properly complete these parts.
18 AFPAM 32-7043 1 November 1995

Figure 3.2. DRMS Form 1930, Hazardous Waste Profile Sheet (Front).
AFPAM 32-7043 1 November 1995 19

Figure 3.3. DRMS Form 1930, Hazardous Waste Profile Sheet (Back).
20 AFPAM 32-7043 1 November 1995

Table 3.2. Hazardous Waste Profile Sheet Instructions.
AFPAM 32-7043 1 November 1995 21

Table 3.2. Continued.
22 AFPAM 32-7043 1 November 1995

Table 3.2. Continued.
AFPAM 32-7043 1 November 1995 23

3.5.2.1. The environmental manager will advise on

completion of Part I and is responsible for completing

information required by EPA land disposal restrictions on

the hazardous waste profile sheet. The environmental

manager is also responsible for reviewing the hazardous

waste profile sheet for accuracy based on the best available

information.

3.5.2.2. Bioenvironmental engineering services will

advise on completion of the health and hazardous waste

identification portions of the hazardous waste profile sheet

in Part II, Sections 1-4, and the special handling

information in Section 5. Bioenvironmental engineering

services also reviews the hazardous waste profile sheet for

technical accuracy when requested by the environmental

manager. Bioenvironmental engineering services should

also maintain a copy of each hazardous waste profile sheet

in the generating activities’ shop folder.

3.5.2.3. The base transportation officer advises on

completion of the proper shipping information,

containers, and transportation requirements of Part II,

Section 5 of the hazardous waste profile sheet.

3.5.2.4. The generating activity is responsible for

completing Part II, Section 6 and attaching a copy of all

Material Safety Data Sheets or identifying the locations

and national stock numbers within the Hazardous

Materials Information System for all chemicals that are

known to be in the waste stream.

3.5.3. Proper Shipping Description. Before a

generating activity can package, mark, label, transport,

and dispose of a hazardous waste, they must identify the

proper shipping description. General guidelines for

identifying the proper shipping description are provided

in chapter 5, table 5.1. The total proper shipping

description (which includes the proper shipping name, the

numerical hazard class or division, the UN or NA

identification number, the packing group, and the

required additional information) must be entered into Part

II, Item 5, on the hazardous waste profile sheet.

3.5.3.1. There are several sources available to assist

generating activities in determining the proper shipping

description. They include the material safety data sheets

provided with all hazardous materials, the Hazardous

Materials Information System, and the markings and/or

labels found on the original hazardous materials

containers. The proper shipping name found on these

items can usually be used with slight modifications,

especially if the waste stream is generated by a single type

of hazardous material. Whenever the above sources are

used to determine the proper shipping description, the

generating activity must verify its accuracy. The proper

shipping description must be listed on the hazardous

waste profile sheet for that waste stream and should match

the requirements described in 49 CFR Part 172, Subpart C

and the Hazardous Materials Table, 49 CFR § 172.101

(see chapter 4 on how to read the Hazardous Materials

Table). If it is not accurate, then the hazardous waste

profile sheet must be updated and accompany the

hazardous waste through turn-in.

3.5.4. Land Disposal Restrictions. Under the 1984

Amendments to RCRA, Congress directed EPA to

prohibit all hazardous wastes from land disposal by 1990

unless the wastes are treated to specific treatment

standards. The treatment standards require wastes to be

treated to certain levels or by specific methods before the

waste can be land filled. The purpose of the land disposal

restrictions is to prevent threats to human health or the

environment caused by leaking land disposal facilities.

The EPA has established land disposal restriction

requirements, published in 40 CFR Part 268, for all

RCRA hazardous wastes. The standards require changes

to recordkeeping procedures and the preparation of

additional paperwork to be shipped with the hazardous

waste manifest. Land disposal restrictions do not apply to

the conditionally exempt small quantity generator.

3.5.4.1. The EPA has established treatment standards on

the basis of the best demonstrated available technology.

"Best" is defined as that technology which offers the

greatest reduction of toxicity, mobility, or volume of the

waste. To be "demonstrated", a treatment technology must

work at a full scale level. To be "available", a treatment

technology must be commercially available. The EPA has

set three treatment standards for restricted wastes:

3.5.4.1.1. Concentration level to be achieved prior to

disposal, the most common type of treatment standard (to

establish a concentration level(s) for a specific hazardous

waste number, the EPA selected a subset of "hazardous

constituents" found in the waste and set standards for

each);

3.5.4.1.2. Specified technology to be used prior to

disposal; and

3.5.4.1.3. “No land disposal" designation, when the waste

is no longer generated, totally recycled, is not currently

being land disposed, or no residuals are produced from

treatment.

3.5.4.2. There are some general guidelines for

determining applicable treatment requirements.

3.5.4.2.1. A generator must determine if a listed waste

exhibits a characteristic.

3.5.4.2.2. If a waste has more than one characteristic

waste number, it must be treated to meet the treatment

standard for each characteristic.

3.5.4.2.3. Mixtures of listed wastes having more than one

applicable concentration-based standard for a particular

constituent must be treated to the most stringent standard

before land disposal is permitted.

3.5.4.2.4. Waste of both listed and characteristic waste

numbers must be treated with the methods that are

required for each listed waste number (in lieu of that

required for the characteristic waste number), provided

that the methods also can remove the characteristic
24 AFPAM 32-7043 1 November 1995

properties. Otherwise, additional treatment must be used

to remove the characteristic properties.

3.5.4.2.5. All residues from the listed wastes are

considered derived-from listed waste and must meet the

same treatment standards as the original listed waste.

Residues from the treatment of characteristic wastes are

considered characteristic only if they display the original

characteristic or if they display another characteristic.

3.5.4.2.6. Soil and debris that are contaminated with

restricted waste are subject to land disposal restrictions

and must meet the treatment standards before disposal is

allowed.

3.5.4.3. The land disposal restrictions establish

requirements for testing, notification, and certification for

compliance.

3.5.4.3.1. Testing. Generators, treatment facilities, and

disposal facilities must test their wastes at a frequency

specified in their waste analysis plans to demonstrate

compliance with land disposal restriction treatment

standards.

3.5.4.3.2. Notification. All restricted wastes that are

shipped to an off-site TSDF must be accompanied by a

notification that includes the EPA hazardous waste

number and the applicable land disposal restrictions for

those wastes.

3.5.4.3.3. Certification. A treatment facility must certify

that land disposal restrictions treatment standards are

attained before a waste is land disposed.

3.5.4.4. In general, dilution of a waste to comply with the

land disposal restrictions is prohibited. However, dilution

that is part of a treatment (e.g. mixing for immobilization)

is permissible.

Table 3.3. Determination of Treatment Standards.

Steps Example

Sandblast grit, TCLP for Chromium = 600 mg/l

Step 1: Determine all EPA hazardous waste numbers

which apply and if the California list applies.

D007 This would not be a California list waste

since it is not a liquid.

Step 2: Determine the treatability subgroup or waste

description (e.g. batteries).

Waste description is chromium.

Step 3: Determine whether the waste is a wastewater

or non-wastewater.(1)

This is a non-wastewater because it is a solid.

Step 4: Look up each hazardous waste number and

determine appropriate treatment standard

found at 40 CFR § 268.41, § 268.42, or §

268.43.

The treatment standard for D007, non-wastewater

is listed at Chromium = 5.0 mg/l.

Step 5: If it is a California list waste, determine

appropriate treatment standard found at §

268.32, § 268.42, and Appendix III.

Not Applicable

Step 6: Determine effective date of regulation. All

RCRA hazardous wastes are regulated.

Effective date of regulation is August 8, 1990.

1. Wastewaters contain less than 1% by weight total organic carbon (TOC) and less than 1% by weight total suspended solids (TSS).

Exception: F001-F005 solvent-water mixtures are defined as wastewaters if they contain less than 1% by weight TOC or 1% by weight

of total F001-F005 solvent constituents listed in § 268.41.

3.5.4.5. The environmental manager must complete the

information required by the EPA on land disposal

restrictions on the hazardous waste profile sheet (see table

3.3). This information can be located in Part 1 of the

hazardous waste profile sheet or as a continuation sheet to

Part 1. In the latter case, the attachment must be clearly

marked as such on the hazardous waste profile sheet. The

following EPA land disposal restriction requirements

must be included on the hazardous waste profile sheet at a

minimum.

3.5.4.5.1. All treatability groups must be listed: e.g.,

wastewater and non-wastewater.

3.5.4.5.2. List all EPA hazardous waste numbers

(sometimes called "codes") in the waste stream (e.g.

D003).

3.5.4.5.3. List all subcategories (e.g. reactive cyanide is a

subcategory to D003-Reactives) (see table 3.4).
AFPAM 32-7043 1 November 1995 25

Table 3.4. Land Disposal Restrictions Subcategories for Characteristic Wastes.

Land Disposal Restriction Subcategories for Characteristic Wastes

The following are RCRA characteristic waste categories for which the EPA established subcategories (treatability groups) in addition to

wastewaters and non-wastewaters.

D001 - Ignitable Subcategories:

 Ignitable Liquids

 Organic Liquids

 Aqueous Liquids

 Wastewaters

 Ignitable Reactives

 Oxidizers

 Ignitable Compressed Gases

D006 - Cadmium Subcategories:

 Wastewaters

 Non-wastewaters

 Cadmium Batteries

D002 - Corrosive Subcategories:

 Acids

 Alkalines (bases)

 Other Corrosives

D007 - Chromium Subcategories:

 Wastewaters

 Non-wastewaters

 Chromium Bricks

 Chromium Batteries

D003 - Reactive Subcategories:

 Reactive Cyanides

 Explosives

 Water Reactives

 Reactive Sulfides

 Other Reactives

D008 - Lead Subcategories:

 Wastewaters

 Non-wastewaters

 Lead-Acid Batteries

Note: Those characteristic wastes not listed here have only wastewater and non-wastewater subcategory

treatability groups.

3.5.4.5.3.1. Enter the 5 letter treatment code(s) (40

CFR § 268.42, Tables 1, 2 and 3) or cite the Code of

Federal Regulation section where the applicable

treatment standard(s) appear in lieu of listing each

treatment standard. One exception to this is that the

treatment standards for each constituent in F001-F005

spent solvents, multi-source leachate (F039), or

California listed wastes must be cited on the hazardous

waste profile sheet.

3.5.4.5.3.2. If a lab pack is involved, describe whether

it contains a waste identified in Appendix IV or V to

40 CFR Part 268. Lab packing for turn-ins to the

DRMO may not be done by the generating activity, but

must be done by the DRMO contractor.

3.5.4.6. The environmental manager is also responsible

for ensuring that the hazardous waste profile sheet is

attached to the manifest along with the applicable land

disposal notifications and certifications.

3.6. Quantification Substep. The final substep in the

hazardous waste characterization process is

quantification. Quantification includes accurately

estimating the amount of hazardous waste generated.

Quantification is documented on the hazardous waste

stream inventory, a compendium of wastes generated or

managed at the installation. The inventory provides

sufficient information regarding each waste to assist in the

overall installation management of all hazardous waste.

The inventory (see table 3.5) must contain, at a minimum,

the following information: identification of the

generating activity; location of the generating activity;

unique waste stream number; waste characterization

information; and disposal methods for the wastes.
26 AFPAM 32-7043 1 November 1995

Table 3.5. Hazardous Waste Stream Inventory and Instructions.

HAZARDOUS WASTE STREAM INVENTORY

Date: 6 Jun 94 Contact Name/Preparer: N. E. Time Telephone Number: (800) 555-1234

Installation: Anywhere Air Force Base Organization Code: 99 EMS

Waste

Stream

Location1

(Shop/Bldg)

Waste

Stream

Number2

Estimated

Quantity

Disposed3

Hazardous

Waste Criteria

Exhibited &

Concentration

Limits4

EPA/State

Hazardous

Waste ID

Number5

EPA Priority

Pollutant

Number6

Disposal

Container7

Disposal

Method8

AMARC

Grid: B-5

Bldg: 207

PO-001

Waste

Paints &

Thinners

4,800 lb/yr

I-Flashpoint

120°

F

(SW-1010)

F-Xylene

(1-11%)

D001, F003 17 Drum DRMO

AMARC

Grid: B-5

Bldg: 207

PO-002

Spent PD

680 Type I

Still Bottom

7,000 lb/yr

I-Flashpoint

95°

F

(SW-1010)

T-Chromium

(150 mg/l)

(SW-6010)

D001, D007 5 Drum

REC

DRMO

(100lbs

still

bottoms

per month

disposed

via

DRMO)

Table continued on next page.
AFPAM 32-7043 1 November 1995 27

Table 3.5. Continued.

HAZARDOUS WASTE STREAM INVENTORY INSTRUCTIONS

General Information. Each organization on-base that generates hazardous waste should be identified by its organization code

and shop code. Tenant organizations, contractors, and others should be identified as specifically as possible. The inventory

should also identify the name and telephone number of at least one point of contact at each generating activity.

1. Identify for each generating activity the building number, shop code, or other specific location, as appropriate, where

hazardous waste is generated. If a generating activity generates waste at several locations, each should be identified. Grid

locations from the hazardous waste management plan location map may be used to identify specific locations for

accumulation sites, initial accumulation point, and TSDF on-base.

2. Each waste stream must be assigned a unique identification number (e.g., AB-001), which consists of a hazardous waste

process code and a locally assigned number. The locally assigned number may be assigned sequentially for each waste

stream generated from a specific process or operation. The hazardous waste process code is assigned from the codes listed in

Table 3.6.

3. Identify the typical and maximum quantity of waste disposed annually. If the waste is infrequently generated,

indicateapproximate frequency.

4. Identify all hazardous waste criteria that the waste exhibits, sampling test results, and the test method used. Use the

following codes: I-Ignitability; C-Corrosivity; R-Reactivity; T-Toxicity; F for F-List Waste; P for P-List Waste; K for K-List

Waste; and U for U-List Waste.

5. Include the EPA hazardous waste number(s) for each waste stream, as well as any applicable state hazardous waste

number(s). Wastes that exhibit one of the four hazardous waste characteristics have the following hazardous waste numbers:

Ignitability- D001; Corrosivity - D002; Reactivity - D003; and Toxicity D004 through D043. The hazardous waste numbers

for other constituents (F-, K-, P-, and U-list wastes) can be found at 40 CFR Part 261.

6. If any of the EPA priority pollutants listed in Table 3.7 are present in the waste stream, the appropriate priority pollutant

identification number should be entered.

7. Indicate type of storage container such as drum, tank (above ground or below ground), or other (e.g., waste pile,

impoundment). Also indicate any special accumulation conditions such as lab pack, pressurized, heated, cooled, etc.

8. Identify the disposition of the waste such as DRMO, recycled on base, base-contracted disposal, or some other form of

recycling or disposal. Disposal Method Codes: CD-Contractor Disposal; DRMO-Disposal by Defense Reutilization and

Marketing Office; SS-Sanitary Sewer; REC-Recycled; ENGY-Burned for Energy Recovery; UIP-Used in Process; and OOther.

3.6.1. Developing the Hazardous Waste Stream Inventory.

Bioenvironmental engineering services develops and maintains

the installation’s hazardous waste stream inventory. In

preparing the inventory, bioenvironmental engineering services

should visit each activity that generates hazardous waste on-base

to confirm data (or lack of data) collected on the hazardous

waste profile sheet and identify any hazardous wastes which

have not been profiled. Bioenvironmental engineering services

may also collect samples during these visits in accordance with

the waste analysis plan to determine if any of the waste streams

encountered are hazardous and should be included in the

inventory.

3.6.1.1. The hazardous waste profile sheet is the primary source

of information used to complete the installation’s hazardous

waste stream inventory. Information concerning waste

generating activities, EPA hazardous waste number, amount of

waste generated, waste characteristics and composition, and

waste shipping information is all included on the hazardous

waste profile sheet. Bioenvironmental engineering services

should review each of the installation’s hazardous waste profile

sheets in order to prepare the hazardous waste stream inventory.

3.6.1.2. The generating activity is responsible for

providing quantity information on all their hazardous

waste streams to bioenvironmental engineering services.

The generating activity estimates the typical and

maximum quantity of waste disposed annually. This

information is included in the installation’s hazardous

waste stream inventory. The generating activity is also

responsible for ensuring that its wastes are accurately

weighed prior to disposal.

3.6.1.3. A sample hazardous waste stream inventory is

included in chapter 3 of the sample hazardous waste

management plan in Attachment 2 of this Guide.
28 AFPAM 32-7043 1 November 1995

Table 3.6. Hazardous Waste Process Codes.

Abrasive Blasting Grit, paint chips, expanded media AB

Aircraft Cleaning Cleaning compounds AC

Battery Shops Battery acid, lead BA

Biological Operations Pesticides such as insecticides, herbicides, rodenticide, etc. BO

Boiler Operations Morpholine, nitrates BL

Chemical Paint Stripping Paint strippers, paint sludge CP

Decarbonizers Nitric acid, sulfuric acid, others DE

Avionics/Electronics Solvents ER

Electroplating Cleaning compounds, chromium, cyanide, tank sludges

contaminated with heavy metals

EP

Expired Shelf Life Expired shelf-life wastes--paints, solvents, cleaning materials,

etc.

ES

Firefighting Operations Aqueous film-forming foam (AFFF) FF

Fluids Change-out/ Purging Oily waste, turbine oil, lube oil, hydraulic fluid, contaminated

fuel, brake fluid, antifreeze, fluid-containing filters

FC

Industrial and Facility Maintenance Cleaning supplies, mercury vapor lamp bulbs, PCBs IM

Industrial Operations Tool and machine wastes, cutting oils IO

Installation Restoration Waste from clean-up of installation restoration program sites IR

Industrial Waste Treatment Wastewater treatment sludge, chlorine IW

Laboratory/NDI Samples, test chemicals, penetrants LA

Medical Mercury, test chemicals, chemotherapeutic drugs ME

Miscellaneous Only wastes which cannot possibly be attributed to any other

process listed

MS

Ordnance, demil/disposal Explosive, pyrotechnic, propellant, lead contaminated water,

soil or dust

OD

One-Time Only Purging underground storage tank prior to replacement OO

Oil Water Separators Contaminated sludge, floating product OS

Painting Operations Paint, paint sludge, filters, surface preparation (solvents) PO

Preservation and Packaging Pentachlorophenol, copper arsenite PP

Photo/X-ray Fixer, developer FX

Research and Development Chemical testing, equipment testing RD

Spill Clean-up Absorbants, rags, contaminated soil SC

Solvents/Degreasing Cold cleaning solvents, PD 680, MEK SO
AFPAM 32-7043 1 November 1995 29

Table 3.7. EPA Priority Pollutants.

Priority Pollutant Air Force Use ID Number

Benzene Fuels 1

Cadmium and compounds Plating for corrosion control 2

Carbon Tetrachloride Bearing cleaning, PMEL 3

Chloroform Bearing shop 4

Chromium and compounds Plating and paints 5

Cyanides Plating solutions 6

Dichloromethane Cold wipedown cleaner 7

Lead and compounds Batteries, paint, solder 8

Mercury and compounds Laboratories 9

Methyl Ethyl Ketone Degreaser/cleaner, aircraft 10

Methyl Isobutyl Ketone Paints 11

Nickel and compounds Plating for corrosion control 12

Perchloroethylene Degreaser 13

Toluene Paints 14

Trichloroethane Parts cleaning, propellants 15

Trichloroethylene Degreaser, parts cleaning 16

Xylene Paints 17

3.7. Documentation. Hazardous waste generators and

operators of TSDFs are required to maintain specific

records and to submit specific reports regarding hazardous

waste generation, accumulation, transportation, disposal,

employee training, and pollution prevention. Generally, a

record must be maintained at each step in the life cycle of

a hazardous waste from initial determination to final

disposal. Additionally, any unusual activity that takes

place during that life-cycle, such as a spill or release, must

also be documented. Installations must keep Air Force,

state, and Federal officials informed through reports

submitted to those agencies at specified intervals.

Individual states may require that additional records and

reports be maintained and submitted.

3.7.1. EPA Identification Number. Each hazardous

waste generator, transporter, and operator of a TSDF must

have a current EPA identification number. The

environmental manager obtains the EPA ID number for

the entire installation. [40 CFR § 262.12, § 263.11, and §

264/265.11]

3.7.2. State Reporting Requirements. State reporting

and recordkeeping requirements may vary from the

Federal requirements. Each installation must develop a

process for identifying and complying with its state

requirements.

3.7.3. Analysis and Test Records. Each generating

activity, the environmental manager and

bioenvironmental engineering services must keep records

of any test results, waste analysis, or other determinations

made to help characterize waste for at least five years

from the date the waste was last sent for treatment,

storage, or disposal. The record of waste analysis is

attached to the hazardous waste profile sheet during turnin. [40 CFR § 262.40(c)]

3.7.4. Hazardous Waste Profile Sheet. A copy of the

hazardous waste profile sheet for each waste stream must

be retained by the generating activity for five years in a

separate hazardous waste file. The environmental

manager and bioenvironmental engineering services will

also maintain copies of all hazardous waste profile sheets.

3.7.5. Hazardous Waste Stream Inventory. The

installation's hazardous waste stream inventory must be

kept current and maintained by bioenvironmental

engineering services and the environmental manager.

3.8. Work Information Management System -

Environmental Subsystem (WIMS-ES). WIMS-ES is a

subsystem of the Civil Engineer's WIMS computer system

and is designed to allow the user to report data in

compliance with the policies outlined in AFPD 32-70,
30 AFPAM 32-7043 1 November 1995

Environmental Quality. It is used to track and report

environmental information to comply with statutory,

regulatory, and administrative requirements. The

information and data reported by the user can be

transferred daily between installations, MAJCOMs, and

the Air Staff. Consult AFI 32-7002, Environmental

Information Management System, for guidance and

procedures.

3.8.1. WIMS-ES Hazardous Waste Module. The

hazardous waste module is used to track hazardous waste

from cradle to grave. There are five kinds of records

within the module:

• Hazardous Waste Management Overview Record (one

per base)

• Waste Stream Record (one per waste stream)

• Container Record (one per container)

• Record of Disposal (ROD) (one per manifest)

• Disposal Site Record (one per disposal site used)

3.8.1.1. There are other records and reporting

requirements in WIMS-ES which impact hazardous waste

management, in the Release Reporting, Pollution

Prevention, and Training modules. Personnel who update

and maintain WIMS-ES data, usually in the

environmental flight, must have a complete understanding

of the system and data collection requirements.

Table 3.8. Typical Wastes Generated at Air Force Installations.

Generating Activity

Type

Characteristic Waste1

D-list

Listed Waste1,2

NonSpecific

Wastes

Discarded, OffSpec, and

Residues3

Ignitable

(D001)

Corro-sive

(D002)

Reactive

(D003)

TCLP F-list P-list

(Acute)

U-list

Corrosion Control:

Spent paint removers, cleaning

solvents, paint thinners

Contaminated paint removers

Spray booth filters, sweepings,

waterfall sludge

Vehicle Maintenance:

Spent paint removers, cleaning

solvents, paint thinners, wiping rags

Contaminated paint removers

Solvent contaminated crank case

and hydraulic oils

Waste oil (see notes)

Caustic cleaners

Battery acid

Table continued on next page.
AFPAM 32-7043 1 November 1995 31

Table 3.8. Continued.

Generating Activity

Type

Characteristic Waste1

D-list

Listed Waste1,2

NonSpecific

Wastes

Discarded, OffSpec, and

Residues3

Ignitable

(D001)

Corrosive

(D002)

Reactive

(D003)

TCLP F-list P-list

(Acute)

U-list

Munitions Management:

Expired shelf-life munitions,

unexploded range munitions, other

munitions and explosives intended

for disposal

Non-Destructive Inspection:

Solvents, penetrants, paint

removers, organic cleaners, wiping

rags

Paint removers, cleaning solvents,

paint thinners

Contaminated paint removers

Laundry:

Dry-cleaning solvent, spent

perchloroethylene,

trichlorotrifluoroethane, petroleum

solvents, still bottoms, spent filter

cartridges, filter muck

Aircraft Maintenance Functions

(Flightline, Munitions, Inspection, and

Repair):

Paint removers, cleaning solvents,

finger print removers, carbon

removers, paint thinners, wiping

rags

Contaminated paint removers

Contaminated waste engine and

hydraulic oils (with solvent)

Contaminated waste engine and

hydraulic oils (with leaded gas)

Waste oil (see notes)

Caustic cleaners and strippers

Battery acid

Table continued on next page.
32 AFPAM 32-7043 1 November 1995

Table 3.8. Continued.

Generating Activity

Type

Characteristic Waste1

D-list

Listed Waste1,2

NonSpecific

Wastes

Discarded, OffSpec, and

Residues3

Ignitable

(D001)

Corro-sive

(D002)

Reactive

(D003)

TCLP F-list P-list

(Acute)

U-list

Base Hospital:

Shelf-life expired drugs

Dental amalgam and mercury from

analytical instruments, broken

thermometers

Unrecovered x-ray lab fixer

solution

Photo-Lab:

Untreated fixer wastewater, scrap

photographic paper

Developer, replenisher, fixer

Pest Management:

Unused pesticide tank mixes

Expired and unused pesticides

Material Labs, Analytical Labs:

Shelf-life expired and unused

reagents intended for disposal, spill

residue, container residue

Mercury removed from analytical

equipment

Plating Shop:

Wastewater treatment sludges

Spent plating baths containing

cyanide

Reproduction and Print Shops:

Blanket wash, spent solvents,

developer

Contaminated inks, ink waste

Notes: 1. If a hazardous waste is mixed with a solid waste, then the resulting mixture is classified as a hazardous waste. Waste oil contaminated

with (mixed with) any hazardous waste must be treated as a hazardous waste. (For off-specification used oil fuel - see 40 CFR Part 279)

2. Specific source (K-list) wastes are generated by specific industries and manufacturing processes. None of these wastes are known to be

generated by the Air Force.

3. Discarded, Off-Spec, and Residues means all Listed Discarded Commercial Products, Off-Specification Species, Container Residues,

and Spill Residues.
AFPAM 32-7043 1 November 1995 33

Federal Requirements Summary

Element Standard

Overview of Subtitle C 40 CFR Part 260, Appendix I

Definitions:

General (for Parts 260-266 & 268)

Solid Waste

Hazardous Waste

40 CFR § 260.10

40 CFR § 261.2

40 CFR § 261.3

Exemptions and Exclusions:

Definitions

Exclusions

Conditionally Exempt Generators

Recyclable Materials

Residues in Empty Containers

PCB Wastes

40 CFR § 261.3

40 CFR § 261.4

40 CFR § 261.5

40 CFR § 261.6

40 CFR § 261.7

40 CFR § 261.8

Representative Sampling Methods 40 CFR Part 261, Appendix I

References 40 CFR § 260.11

Characteristic Wastes:

Ignitability

Corrosivity

Reactivity

Toxicity

40 CFR § 261.21

40 CFR § 261.22

40 CFR § 261.23

40 CFR § 260.11 & 261.24

Listed Wastes:

Non-specific Source (F-list)

Specific Source (K-list)

Discarded Commercial (P-list & U-list)

Acute Hazardous Waste

40 CFR § 261.31

40 CFR § 261.32

40 CFR § 261.33

40 CFR § 261.31 to 261.33

Mixtures 40 CFR § 261.3

Waste Analysis and Recordkeeping

Analysis and Test Records

40 CFR § 268.7(a) & 262.11

40 CFR § 262.40(c)

40 CFR § 264/265.13

EPA Identification Number:

Generator

Transporter

Interim Status/Permitted Facility

40 CFR § 262.12

40 CFR § 263.11

40 CFR § 264/265.11

Table continued on next page.
34 AFPAM 32-7043 1 November 1995

Federal Requirements Summary

Element Standard

Land Disposal Restrictions:

Definitions

Dilution Prohibited

Notification of Restricted Waste

Certification for Land Disposal

Exemption

Generator Treatment of Waste

Documentation

Lab Packs

Recycled Waste for Small Quantity

Generators

Characteristic Waste Special Rules

Solvent Waste

Dioxin-Containing Wastes

California List Wastes

First Third Wastes

Second Third Wastes

Third Third Wastes

Ignitable and Corrosive Wastes

Treatment Standards Applicability

Constituent Concentrations in Waste

Extract (CCWE Table)

Technology-Based Standards

Constituent Concentrations in Waste

(CCW Table)

Storage Prohibitions

40 CFR § 268.2

40 CFR § 268.3

40 CFR § 268.7(a)(1)

40 CFR § 268.7(a)(2)

40 CFR § 268.7(a)(3)

40 CFR § 268.7(a)(4)

40 CFR § 268.7(a)(5) to (a)(7)

40 CFR § 268.7(a)(8) & (a)(9)

40 CFR § 268.7(a)(10)

40 CFR § 268.9

40 CFR § 268.30

40 CFR § 268.31

40 CFR § 268.32

40 CFR § 268.33

40 CFR § 268.34

40 CFR § 268.35

40 CFR § 268.37

40 CFR § 268.40

40 CFR § 268.41

40 CFR § 268.42

40 CFR § 268.43

40 CFR § 268.50

____________________________________________________________________________________________________

Chapter 4

HAZARDOUS WASTE STORAGE

(CONTAINER MANAGEMENT, GENERATOR CLASSIFICATION, AND

ACCUMULATION MANAGEMENT)

GENERATION

PHASE

STORAGE

PHASE

DISPOSAL

PHASE

CHARACTERIZATION STEP

CONTAINER/

TANK MNGT

STEP

GENERATOR

CLASSIFICATION STEP

ACCUMULATION MNGT

STEP

TURN-IN

STEP

TRANSPORT

STEP

DISPOSAL STEP

4.1. Overview. As hazardous waste is being generated

and characterized, it must be properly stored. The Storage

Phase, which is the second Phase of the hazardous waste

life-cycle (see Figure 4.1), has three steps: container/tank

management, generator classification, and accumulation

management. Container/tank management includes

selecting the proper containers and tanks to accumulate

and transport hazardous waste, and the proper handling
AFPAM 32-7043 1 November 1995 35

and storing of each. Generator classification is

determining the type of generator for each AF installation,

based on the quantity of hazardous waste and acute

hazardous waste generated each month. Generator

classification determines specific storage requirements in

the accumulation management step. Accumulation

management includes selecting and designing the proper

site(s) for accumulation of the hazardous waste.

4.2. Container Management. Hazardous waste must be

stored in EPA approved containers or tanks.

4.2.1. Container Selection. Since hazardous waste most

likely be transported in the container in which it is

collected and stored, select the proper hazardous waste

container based on the DOT Hazardous Materials Table

listed at 49 CFR § 172.101 (see table 4.1). Hazardous

materials description and proper shipping names are listed

in alphabetical order. In selecting the proper container,

the user searches the table for the hazardous material that

generates the hazardous waste and identifies the

packaging requirements. Column 7 of the table refers to

special provisions for packaging and transportation (see

table 4.1). Column 8 of the table identifies the specific

packaging requirements for bulk and non-bulk packaging

found under 49 CFR Part 173 (see table 4.2). See chapter

5 for an explanation on the proper shipping name.

4.2.1.1. For example, if the waste generated is spent

sulfuric acid, look up "sulfuric acid, spent" in the

Hazardous Materials Table. Column 7 lists the following

special provision codes: A3 and A7 (aircraft

requirements); B2, B83, and B84 (bulk packaging); N34

(non-bulk packaging); and T9 and T37 (inter-modals).

After reviewing the special provision codes, the only one

which affects our container selection is N34: "Aluminum

construction materials are not authorized for any part of a

packaging which is normally in contact with the

hazardous material."

4.2.1.2. Column 8(b) of the hazardous materials table

identifies the authorized non-bulk packaging listed at 49

CFR § 173.202. Reviewing this paragraph shows

multiple combination and single container types that can

be used for spent sulfuric acid, except for aluminum,

which is prohibited by the special provision in column 7.

4.2.2. Specification Packaging Versus PerformanceOriented Packaging. DOT has moved from detailed

construction specification packaging to performanceoriented packaging to compete with international

shipping. This section of Chapter 4 is based on the latest

edition of Title 49, which includes performance-oriented

packaging (HM-181) requirements. The previously issued

hazardous materials table (in effect on 30 September

1991), which specifies DOT specification containers, can

still be used until 1 October 1996, unless the hazardous

waste is poisonous by inhalation, an explosive, or an

infectious substance.

4.2.3. Container Condition. Most hazardous waste

containers on Air Force installations are 55-gallon drums.

All containers storing hazardous waste must be in good

condition. Good condition means there should be no

severe rusting, no sharp-edged creases or dents, no

bulging heads caused by overpressuring a container

(usually from overfilling), and no severe structural

defects. If a container is not in good condition or begins

to leak, the hazardous waste must be immediately

transferred to another container or overpacked in a

salvage drum. Containers with pools of hazardous waste

on the top must be decontaminated or overpacked. [40

CFR § 264/265.171 ]

4.2.4. Container Opening. Follow proper procedures

when opening, filling, and handling a container. Use

bung wrenches to open a closed (non-removable) head

drum. Removable head drums are opened by loosening

the nut on the retaining ring, removing the retaining ring,

and then removing the drum head. If the material in the

drum is combustible or flammable, spark-proof wrenches

(made from bronze or aluminum) should be used to

prevent accidental ignition of the waste due to sparks.

Slowly loosen the bung or retaining ring to allow for any

pressure buildup to dissipate. [40 CFR § 264/265.173]

4.2.5. Container Filling. Do not overfill containers; fill

to 90% of capacity. For example, only fill a 55-gallon

drum to 50 gallons. Liquids expand in containers as the

temperature increases. The pressure created by the

expansion of the liquid in a completely filled container

causes bulging heads and damages the integrity of the

container. Bulging containers also create a safety hazard

for personnel adding waste to or handling containers. Use

a funnel in the bung to fill closed head containers. This

will ensure that all waste is poured into the container and

does not spill on the top of the container. After filling, the

funnel should be removed and the container closed. If the

funnel has any hazardous waste residues remaining, the

residues should be rinsed into the container, or the funnel

placed in a suitable closed hazardous waste accumulation

container. Keep containers closed unless adding or

removing waste. To prevent improper mixing, containers

must be kept in a secured area. [40 CFR § 264/265.173

and 49 CFR § 173.24(h)]

4.2.6. Container Handling. Handle drums and other

containers with equipment designed for the task. Secure

containers to pallets before moving pallets. Use drum

carts designed for the container types to reduce the

likelihood of dropping a container during handling.

Never balance drums on the forks of a forklift or tow

motor. Do not stack drums more than two high. Drums

containing flammable liquids should not be stacked. Do

not allow the movement
36 AFPAM 32-7043 1 November 1995

Figure 4.1. Storage Phase of Hazardous Waste Life-Cycle.
AFPAM 32-7043 1 November 1995 37

Table 4.1. Sample Hazardous Materials Table and Column Explanation.
38 AFPAM 32-7043 1 November 1995

Table 4.2. Performance-Oriented Packaging Codes for Non-bulk Packaging.

Identification Codes for Non-bulk Packaging

Types of Packaging Material of Construction Category of Packaging

1 drum A steel For steel drums (1A), a "1" indicates a

non-removable head drum (i.e., "1A1");

and a "2" indicates a removable head

drum (i.e., "1A2").

2 wooden barrel B aluminum Composite Packaging

3 jerrican C natural wood 2 capital letters are used in sequence in

the second position of the code, the first

4 box D plywood indicates inner material and second is

the outer packaging. Example: plastic

5 bag F reconstituted wood receptacle in a steel drum is designated

"6HA1."

6 composite packaging G fiberboard Combination Packaging

7 pressure receptacle H plastic Only the code number for the outer

packaging is used.

Example:

UN 1A1 / Y 1.4/ 150 / 84

 Test Code

 Category

 Material

 Type

L

M

N

textile

paper, multi-wall

metal (other than steel

or aluminum)

Test Performance Standard meets

X - PG I, II and III tests

Y - meets PG II and III tests

Z - only meets PG III tests

P glass, porcelain or

stoneware

of vehicles such as trucks, fork lifts, POV's, etc., in or

near the container storage area unless loading or

unloading. If containers must be stored outdoors, store

them in an area protected from precipitation, whenever

possible.

4.2.7. Containers with Ignitable or Reactive Waste.

Containers accumulating ignitable or reactive waste must

be located at least 50 feet away from (inside) the

installation property boundary. These containers must

also be kept away from sparks, open flames, extreme heat,

or other sources of ignition. Grounding and bonding may

be required for flammable wastes. [40 CFR § 264/265.17

and 264/265.176]

4.2.8. Empty Containers. All empty chemical and waste

containers must be responsibly managed to prevent

contamination of the environment from residues and to

comply with EPA and DOT regulations. A properly

managed empty drum may be exempt from hazardous

waste regulations. A container or an inner liner removed

from a container that held hazardous waste is classified as

empty and is not regulated as a hazardous waste if the

following conditions are met:

• All waste that can be removed by common methods

has been accomplished; and

• Less than one inch remains in the bottom; or

• No more than 3% of the total capacity by weight

remains for containers less than or equal to 110

gallons; or

• No more than 0.3% of the total capacity by weight for

containers greater than 110 gallons.

4.2.8.1. Acute hazardous waste containers are considered

empty when the container or inner liner is free of product

by proper triple rinsing or cleaning, or the inner liner is

removed. Hazardous waste compressed gas containers are

empty when container pressure approaches atmospheric

pressure. [40 CFR § 261.7 and 49 CFR § 173.29]

4.2.9. Marking Hazardous Waste Containers for

Accumulation. Each container must be marked with the

words "Hazardous Waste" and with the date initial
AFPAM 32-7043 1 November 1995 39

accumulation began, or when the volume limit was met

for initial accumulation points (see paragraph 4.5.1).

Containers should also be marked with a unique container

identification number assigned by the accumulation site

manager once the accumulation time limit starts. It is

recommended that the waste stream contents be marked

on the container. All marking should be large enough

(one to two inches) to be seen from a distance. [40 CFR §

262.34(a)(2)(3) and (c)]

4.2.10. Container Inspection. All containers must be

inspected at least weekly for potential release problems.

[40 CFR § 264/265.174]

4.3. Tank Management. Hazardous waste stored in

tanks must meet very specific requirements due to the

large volume of hazardous waste in tanks that could be

released during an incident. Basically, tank systems must

be properly designed and installed, have adequate

corrosion protection, employ secondary containment, be

capable of detecting releases of hazardous waste, be

operated to prevent releases, and be inspected according to

the requirements. For existing tank systems less than 15

years old which do not have secondary containment, the

installation must conduct an assessment of the tank to

ensure the tank is not leaking and is fit for use. The

assessment must be conducted by an independent,

qualified professional engineer and must be properly

documented. The assessment to ensure the tank system is

adequately designed and has the strength and

compatibility to hold the hazardous waste must consider

the following:

4.3.1. Design standards, if available, according to which

the tank and ancillary equipment were constructed;

4.3.2. Hazardous characteristics of the wastes that have

been or will be handled;

4.3.3. Existing corrosion protection measures;

4.3.4. Documented age of the tank system, if available

(otherwise estimate the age of the tank); and

4.3.5. Results of a leak test, internal inspection, or other

tank integrity examination. [40 CFR § 262.34, and 40

CFR Part 265, Subpart J]

4.4. Generator Classification. There are three

categories of generators based upon the type and volume

of hazardous waste an installation generates (determined

during hazardous waste quantification) and accumulation

time: large quantity generator, small quantity generator,

and conditionally exempt small quantity generator. As

the volume of hazardous waste generated increases, so

does the level of regulation placed upon the generator.

Although different shops and activities within the

installation (known as generating activities) generate

hazardous waste, the installation as a whole is classified

as a single generator.

4.4.1. Large Quantity Generator. A large quantity

generator either produces 1,000 or more kilograms (kg) of

hazardous waste per month (approximately 265 gallons or

2,200 lbs) OR produces 1 kg or more of acute hazardous

waste per month. As a large quantity generator, the

installation can accumulate an unlimited volume of

hazardous waste for up to 90 days. [40 CFR § 262.34(a)

and (c)]

4.4.2. Small Quantity Generator. To be classified as a

small quantity generator, the installation must generate

less than 1,000 kg but more than 100 kg (approximately

25 gallons or 220 lbs) hazardous waste AND generates 1

kg or less of acute hazardous waste per month. If either of

the quantities is exceeded, the installation would be

classified as a large quantity generator. A small quantity

generator may accumulate a volume of 6,000 kg of

hazardous waste for up to 180 days. The time is extended

to 270 days if the TSDF is 200 or more miles away. [40

CFR § 262.34(d) and (e)]

4.4.3. Conditionally Exempt Small Quantity

Generator. As a conditionally exempt small quantity

generator, the installation must produce no more than 100

kg of hazardous waste per month and less than 1 kg of

acute hazardous waste (or 100 kg of soil, waste, or debris

from an acute hazardous waste spill clean up) per month.

Any time these quantities are exceeded, the conditionally

exempt small quantity generator immediately becomes a

small quantity generator. The conditionally exempt small

quantity generator is exempt from many of the RCRA

requirements. Any installation that believes it fits into

this category must carefully research and document their

decision making process. Conditionally exempt small

quantity generators must treat and dispose of their

hazardous waste in approved hazardous waste TSDFs or

in facilities authorized to manage municipal or industrial

solid waste. [40 CFR § 261.5]

4.4.4. Permitted Storage Facilities. If a large quantity

generator or small quantity generator exceeds their waste

accumulation times (90 days for large quantity generator;

180 or 270 days for small quantity generator) without a

time extension from the EPA, they are considered an

operator of a storage facility. They must apply for a

permit (40 CFR Part 270) and operate under interim

status standards (40 CFR Part 265). Once they receive

their Part B permit, they operate under permitted

standards (40 CFR Part 264) and OSHA Standard 29 CFR

1910.120(p). [40 CFR § 262.34(b) and (f)]

4.4.4.1. Hazardous waste TSDFs are subject to a

permitting system that strives to ensure safe operation.

Under this permitting system, facilities must meet general

standards for proper waste management and requirements

specific to the individual facility. Facilities that store

hazardous waste, except for hazardous waste generators

that accumulate hazardous waste in accordance with the

time limitations noted above, must obtain a Part B permit

for their storage activities. At Air Force installations,

storage facilities are typically either operated by one of the

Air Force organizations on-base, such as the civil
40 AFPAM 32-7043 1 November 1995

engineer squadrons, or by DRMO. Storage may occur in

either tanks or containers. Due to land disposal

restrictions, hazardous waste may not be stored for over

one year.

4.5. Accumulation Management. Accumulation

management includes three different periods of

accumulation: initial accumulation at the initial

accumulation point, temporary or interim accumulation at

the accumulation site, and extended storage at permitted

storage facilities.

4.5.1. Initial Accumulation (Satellite) Point. Generally,

an initial accumulation (satellite) point is an accumulation

area close to the generating activity. Accumulation

continues at an initial accumulation point until 55 gallons

of hazardous waste or 1 quart of acute hazardous waste is

collected. Once the 55-gallon or 1-quart limit is reached,

the generating activity must transfer the hazardous waste

container to an accumulation site within three days. At

that time a generator is required to comply with all

applicable RCRA requirements with regard to 40 CFR §

262.34(a). The 90-day storage period begins as soon as

the three-day period has expired and the excess amount

becomes subject to 40 CFR § 262.34(a) requirement.

Some states do not recognize initial accumulation points

and consider the 90-day limit to begin when the first drop

of hazardous waste is placed into the container. [40 CFR

§ 262.34(c)]

4.5.1.1. Containers must be kept in a secure area to

prevent accidental mixing of wastes and to maintain the

validity of the container's contents without costly analysis.

A system which provides security and secondary

containment is recommended. Basic requirements for fire

protection, worker safety and health, and reducing

environmental harm should be considered in the location

of an initial accumulation point.

4.5.2. Accumulation Site. When the generating activity

is ready to transfer their hazardous waste from the initial

accumulation point, the hazardous waste is transferred to

the accumulation site, a centralized location where wastes

from several generating activities are placed for up to 90

days for large quantity generators, 180 or 270 days for

small quantity generators. Due to the inherent risks

associated with large volumes of hazardous waste, it is

imperative that consideration be given to the design,

selection, and management of the accumulation site. [40

CFR § 262.34]

4.5.2.1. The accumulation site selection should be one

that minimizes the threat of the hazardous waste to both

human health and the environment in the event of a

release of hazardous waste or hazardous waste

constituents. The following factors should be considered

in the selection of the accumulation site:

4.5.2.1.1. EPA and state location and design

requirements;

4.5.2.1.2. Fire protection, worker health and safety,

public health and safety, and environmental (ecological)

requirements and issues;

4.5.2.1.3. Space for waste segregation requirements;

4.5.2.1.4. Liability for hazardous waste clean up; and

4.5.2.1.5. Sufficient area for containers that hold

ignitable or reactive wastes to provide at least 15 meters

(50 feet) from (within) the installation's property line.

4.5.2.2. Once the accumulation site has been selected,

consideration must be given to design of the container

systems. The EPA does not require impermeable bases or

containment systems at accumulation sites used for

container storage for large quantity generators and small

quantity generators; however, many states do, and

impermeable bases or containment systems must be

provided for permitted storage facilities. Considerations

for the design of 90-day accumulation sites for containers

include the following.

4.5.2.2.1. Provide an impervious surface free from cracks

and gaps, treated with a sealant to prevent spills from

contacting the ground. Containers should not be placed

on dirt, sand, gravel, or grass surfaces.

4.5.2.2.2. Locate accumulation sites away from any floor

drains that lead to sanitary or storm water sewers.

4.5.2.2.3. Provide a containment system with a capacity

to either contain the volume of the largest container or ten

percent of the volume of all containers, whichever is

greater.

4.5.2.2.4. Slope the base of the containment system to a

sump so liquids resulting from leaks, spills, or

precipitation are drained and removed, unless containers

are elevated.

4.5.2.2.5. Prevent run-on into the container area, or

provide a containment system with enough excess

capacity so any run-on will be contained along with the

largest spill capacity.

4.5.2.2.6. For incompatible wastes, provide segregated

containment by using either separate containment areas,

by means of separately diked areas, or by sloped

containment to separate sumps. [40 CFR § 265.177]

4.5.2.2.7. Erect a fence with a means to control entry

around the accumulation site and post signs "Danger--

Unauthorized Personnel Keep Out" (in English and any

other language predominant in the area) that can be seen

from any access and are large enough to be read from 25

feet.

4.5.2.2.8. Cover containers accumulated outdoors with a

roof or with a tarpaulin to protect volatile materials from

direct sunlight, causing expansion and pressure build-up

in the container which could lead to container failure and

hazardous waste release.

4.5.2.2.9. Ventilate confined areas (enclosed storage

buildings) used for the accumulation of hazardous wastes.

A build up of hazardous waste vapors can present a

serious health hazard for toxic hazardous waste or fire

ignition hazard for flammable hazardous waste.
AFPAM 32-7043 1 November 1995 41

Electrical exhaust systems must meet the National

Electrical Code if flammable hazardous waste is present.

Exhaust systems must take into consideration whether the

hazardous waste vapors are heavier or lighter than air.

Ensure exhausted air does not reenter work areas.

4.5.2.2.10. Place drums on pallets to allow for ease of

removal when full.

4.5.3. Accumulation Site Logs. Logs are maintained at

accumulation sites to track each hazardous waste

container (see figure 4.2). Logs include a base designated

number for each waste stream using the Air Force

hazardous waste process codes (see table 3.6) and a base

designated sequential number for each container; the

container's contents (waste stream); the accumulation start

date; date the container is full; the date the container was

transferred or turned in; and the container's disposition

(shipped to DRMO or TSDF).

4.5.4. Inspection Records. Containers and tanks at

accumulation sites must be inspected either daily (tanks)

or weekly (containers). An inspection checklist should be

developed to ensure consistency in all inspections and

incorporated into the hazardous waste management plan.

It is also recommended that containers at initial

accumulation points be inspected daily. The EPA does

not require inspection records or logs at accumulation

sites; however many states do, and they are required at

permitted facilities. Inspection records/logs should

include the date, inspector’s name, and actions taken to

remedy any problems identified. Inspection records must

be maintained for at least three years from the date of each

inspection. [40 CFR § 262.34(a) & (d), and Part 265

Subparts I/J]

4.5.4.1. Sometimes DRMO will accept accountability of

the hazardous waste once it is turned in, but not take

physical custody. This is normally when the installation

has the most nearly conforming storage (to 40 CFR Parts

264/265), when there is no available storage space at

DRMO, or when the DRMO is staffed by one person and

it becomes a safety issue. When DRMO accepts the turnin of hazardous waste in-place, the generating activity or

accumulation site with physical custody of the waste is

responsible for required periodic inspections and care and

protection of the hazardous waste until it is disposed of by

the DRMO. If waste is accumulated in-place in excess of

90 days (180/270 days for small quantity generators) the

generating activity must obtain the necessary permit for a

TSDF.

4.5.5. Selection of Initial Accumulation Point

Managers and Alternates. Each generating activity

assigns a primary and alternate initial accumulation point

manager for the waste streams they generate. Managers

are normally the shop supervisors and their assistants for

shops that generate hazardous waste. Initial accumulation

point managers and alternates are responsible for the

following activities:

4.5.5.1. Providing safe equipment and locations for initial

accumulation points;

4.5.5.2. Coordinating each location with accumulation

site manager, environmental manager, ground safety, fire

protection, and bioenvironmental engineering services;

4.5.5.3. Ensuring hazardous waste accumulation

complies with Federal, state, and local hazardous waste

management requirements; and

4.5.5.4. Ensuring all personnel that handle hazardous

waste at the initial accumulation points receive annual

training.

4.5.6. Selection of Accumulation Site Managers and

Alternates. Each generating activity which has an

accumulation site must appoint an accumulation site

manager and alternate. Site managers must accomplish

the following:

4.5.6.1. Assume overall responsibility for management of

the hazardous waste accumulation site;

4.5.6.2. Coordinate requirements and problems with

environmental manager, ground safety, fire protection,

and the bioenvironmental engineering services;

4.5.6.3. Ensure accumulation site has appropriate

warning signs;

4.5.6.4. Ensure accumulation site has appropriate

spill/release response kit and personnel are properly

trained in its use;

4.5.6.5. Ensure approved fire extinguishers are readily

available if flammable hazardous waste is stored in the

accumulation site and personnel are properly trained in

their use;

4.5.6.6. Perform and document inspections of the

accumulation site; inspections must be performed weekly

for containers and daily for tanks;

4.5.6.7. Ensure that hazardous wastes are collected and

stored in approved containers and tanks;

4.5.6.8. Maintain hazardous waste containers in proper

condition, e.g., no pitting, no sharp edge creases or dents,

no material defects, no bulging heads;

4.5.6.9. Ensure that containers are kept closed except

when they are being filled;

4.5.6.10. Ensure that all hazardous wastes from their

assigned initial accumulation points are placed in their

accumulation site;

4.5.6.11. Ensure that hazardous waste is not placed in a

container that is not properly marked;

4.5.6.12. Ensure that hazardous waste containers are

properly painted/marked before they receive any

hazardous waste;

4.5.6.13. Ensure that the placement of a new hazardous

waste container in its accumulation site is accompanied by

a simultaneous entry of the placement in the accumulation

site log;
42 AFPAM 32-7043 1 November 1995

Figure 4.2. Accumulation Site Log and Instructions.

Accumulation Site Log and Instructions

Container # Waste Stream Start Date Date Full Date

Transferred

Shipped To

AB-001-037 Sand blasting waste 5 Jul 94 5 Jul 94 1 Oct 94 DRMO

AB-001-038 Sand blasting waste 6 Jul 94 6 Jul 94 1 Oct 94 DRMO

AB-001-039 Sand blasting waste 10 Jul 94 10 Jul 94 1 Oct 94 DRMO

FC-001-143 Contaminated JP-4 8 Aug 94 30 Aug 94 1 Oct 94 Ajax Recycling

PO-002-057 Spent PD 680 9 Aug 94 15 Sep 94 5 Nov 94 DRMO

AC-004-10 Solvent

contaminated rags

3 Sep 94 15 Oct 94 5 Nov 94 DRMO

Container # - Use waste stream number assigned (AB-001, PO-002, etc.) and consecutive number for each container (-001, -002, -

003, etc.). The waste stream number is used as a cross reference tool for linking waste container, turn-in document, sample and chainof-custody forms, hazardous waste inventories, and other appropriate records. Example: AB-001-037 is the 37th drum of paint

chips generated by an abrasive blasting process. 

Waste Stream - Enter a brief description of the hazardous waste in each container.

Start Date - If waste is added to a container at an accumulation site, enter the date the first volume of waste was added to the

container. If a 55-gallon container is used at an initial accumulation point and subsequently moved to the accumulation site, enter the

date the container was filled to capacity. If the container is less than full, enter the date the container was moved to the accumulation

site.

Date Full - Enter the date the container was filled to capacity.

Date Transferred - Enter the date the container was transferred to DRMO or shipped to a TSDF.

Shipped To - Enter location to which container was shipped.

4.5.6.14. Ensure the storage of hazardous waste in the

accumulation site does not exceed 90 days (180/270 days

for small quantity generators);

4.5.6.15. Ensure initial hazardous waste management

training is provided to personnel before they handle

hazardous waste; coordinate training with environmental

manager and ensure proper documentation;

4.5.6.16. Ensure annual hazardous waste management

refresher training is provided to all personnel who handle

hazardous waste and document the training;

4.5.6.17. Properly annotate the AF Form 2005 and DD

Form 1348, complete and update DRMS Form 1930 prior

to processing the hazardous waste for turn-in and

disposal;

4.5.6.18. Implement remedial action when a hazardous

waste spill/release is detected; stop all other actions and

contain spill to best of ability based on unit capability and

resources; initiate base response by immediately notifying

appropriate agency; and

4.5.6.19. Maintain all hazardous waste documentation

and correspondence for a minimum of 3 years.

4.5.8. Closing an Accumulation Site. When closing an

accumulation site, the installation must control, minimize,

or eliminate, to the extent necessary to protect human

health and the environment, the post-closure escape of

hazardous waste and constituents, and minimize the need

for further maintenance. This includes removing or

preventing the escape of any hazardous waste, hazardous

constituents, leachate, contaminated run-off, or hazardous

waste decomposition products to the ground, surface

water, or the atmosphere. During closure, all

contaminated equipment, structures, and soil must be

properly disposed of or decontaminated. [40 CFR §

262.34(a), § 265.111, and § 265.114]

4.6. TSDF Documentation Requirements. If the

installation operates a permitted storage facility, there are

specific documentation requirements.

4.6.1. Operating Record. Each permitted and interim

status facility must maintain an operating record which

contains the following: specific information (description

and quantity) on all hazardous wastes stored at the

facility; the date they were processed; their location; waste

analysis records; incident summaries and reports;

monitoring, testing or analytical data; waste minimization

documentation; and records of land disposal use. [40 CFR

§ 264/265.73 & 74]

4.6.2. Unmanifested Shipment Report. Permitted and

interim status TSDFs may accept unmanifested waste

from conditionally exempt small quantity generators if

certification that the generator qualifies for exclusion can

be obtained. If certification cannot be obtained, the

facility operator must report the situation to the EPA

within 15 days of receiving the waste. The report includes

the following: name, address and EPA ID number; date

the waste was received; name, address and EPA ID

number of the generator and transporter; description and
AFPAM 32-7043 1 November 1995 43

quantity of the waste; method of treatment or storage;

certification signed by the operator of the installation; and

to the extent known, a brief explanation why the wastes

were not properly manifested. [40 CFR § 264/265.76]

4.6.3. New Tank Assessment. TSDFs with new tank

systems storing hazardous waste must obtain a written

assessment review certified by an independent, qualified,

registered professional engineer. The purpose is to certify

that the tanks and the installation meet the required EPA

standards. For permitted TSDFs, this assessment must be

submitted to the EPA Administrator with the Part B

permit. [40 CFR § 264.192]

4.6.4. Groundwater Assessment Record. TSDFs that

include surface impoundments, waste piles, land

treatment units or landfills must monitor groundwater,

record the results of all analyses, evaluations and

assessments, and report results to the EPA Administrator

in accordance with applicable schedules. [Subpart F of 40

CFR Parts 264 & 265]

4.6.5. Semi-Annual Inspections of Corrective Action

Progress Reports, New Cathodic Protection Systems,

Vent Emissions, and Annual Inspections of TSDFs.

There are specific requirements for permitted and interim

status facilities concerning clean-up activities, corrosion

protection for underground tanks, reporting of air

emissions, groundwater monitoring, and inspections.

Personnel who work at a permitted storage facility should

review the Federal requirements listed below for TSDFs to

ensure they are in compliance.
44 AFPAM 32-7043 1 November 1995

Federal Requirements Summary

Large Quantity (LQ); Small Quantity (SQ); Conditionally Exempt Small Quantity (CEQ); Permitted Storage Facility (PSF)

Element Standard LQ SQ CEQ PSF

Generator Classification:

Large Quantity

Small Quantity

Conditionally Exempt

Permitted Facility

40 CFR § 262.34(a)(c)

40 CFR § 262.34(d)(f)

40 CFR § 261.5

40 CFR § 262.34(b)(f)

Accumulation Times:

90 days

180 days

270 days

Time Extensions

Over Quantity Limits

40 CFR § 262.34(a)

40 CFR § 262.34(d)

40 CFR § 262.34(e)

40 CFR § 262.34(b)(f)

40 CFR § 261.5(e)(g)

40 CFR § 262.34(b)(f)

Containers:

Condition

Compatability

Opening

Filling

Handling

Ignitable, Reactive, or Incompatible Wastes

Empties

Marking

Inspections

40 CFR 264/265 Subpart I

40 CFR § 264/265.171

40 CFR § 264/265.172

49 CFR § 173.24(e)

40 CFR § 264/265.173

40 CFR § 264/265.173

49 CFR § 173.24(h)

40 CFR § 264/265.173

40 CFR § 264/265.17,

176 & 177

49 CFR § 173.24

40 CFR § 261.7

49 CFR § 173.29

40 CFR § 262.34(a)(c)

40 CFR § 264/265.174

Exceptions for Shipment - Hazardous Waste:

Open Head Drums

Lab Packs

Reuse of Packaging

49 CFR § 173.12(a)

49 CFR § 173.12(b)

40 CFR § 264/265.316

49 CFR § 173.12(c)

General Packaging Requirements 49 CFR § 173.24 & 173.24a

Salvage Drums 49 CFR § 173.3(c)

Table continued on next page.
AFPAM 32-7043 1 November 1995 45

Large Quantity (LQ); Small Quantity (SQ); Conditionally Exempt Small Quantity (CEQ); Permitted Storage Facility (PSF)

Element Standard LQ SQ CEQ PSF

Reuse of Packaging 49 CFR § 173.28(b)(6)

Tank Systems:

Assessing Existing Tank Integrity

New Tanks

Release Detection and Containment

General Operating Requirements

Inspections

Leaks or Spills/Unfit Tanks

Ignitable or Reactive Wastes

Incompatible Wastes

Waste Analysis

Small Quantity Generators

40 CFR § 262.34

40 CFR 264/265 Subpart J

40 CFR § 264/265.191

40 CFR § 264/265.192

40 CFR § 264/265.193

40 CFR § 264/265.194

40 CFR § 264/265.195

40 CFR § 264/265.196

40 CFR § 264/265.198

40 CFR § 264/265.199

40 CFR § 265.200

40 CFR § 265.201

Accumulation Site Log (**There is no direct

reference to maintaining accumulation site logs.

It is Air Force policy to maintain this log to

document that all hazardous waste containers

are properly handled within the allotted time

frame.)

40 CFR § 262.34**

Inspection Records (**There is no EPA

requirement for initial accumulation points or

90-day accumulation sites to maintain inspection

records/logs. It is, however, Air Force policy to

maintain such records to document that required

inspections are being conducted. Also, certain

states may require maintenance of inspection

records.)

Containers

Tanks

Corrective Action Progress

Cathodic Protection Systems

TSDF Vent Emissions

40 CFR § 264/265.174

40 CFR § 264/265.195

40 CFR § 264.100

40 CFR § 264/265.75 & .195

40 CFR § 264.1036

TSDFs:

Operating Records

Unmanifested Shipments

New Tank Assessment

Groundwater Monitoring

40 CFR § 264/265.73 & 74

40 CFR § 264/265.76

40 CFR § 264.192

40 CFR § 265.94
46 AFPAM 32-7043 1 November 1995

____________________________________________________________________________________________________

Chapter 5

HAZARDOUS WASTE DISPOSAL

(TURN-IN, TRANSPORT, AND DISPOSAL)

GENERATION

PHASE

STORAGE

PHASE

DISPOSAL

PHASE

HAZARDOUS

WASTE

CHARACTERIZATION STEP

CONTAINER/

TANK MNGT

STEP

GENERATOR

CLASSIFICATION STEP

ACCUMULATION

MNGT STEP

TURN-IN

STEP

TRANSPORT

STEP

DISPOSAL

STEP

5.1. Overview. The final phase of the hazardous waste

life-cycle is disposal, involving the three steps of turn-in,

transport, and disposal. As seen in figure 5.1, the disposal

phase begins when the generating activity is ready to turn

in their hazardous waste. Turn-in is the transfer of

authority to properly dispose of the hazardous waste,

usually to DRMO. Once turned in, the hazardous waste is

transported to a RCRA-permitted facility for ultimate

disposal. The disposal phase requires a coordinated effort

by all installation personnel including the generating

activity, the environmental flight, bioenvironmental

engineering services, accounting and finance, contracting,

and the disposal agent, normally DRMO. The entire

disposal phase of the hazardous waste life-cycle is guided

by documentation which must be completed throughout

the turn-in, transport, and disposal steps. Transportation

is a critical link of the hazardous waste life-cycle

management process. Correspondingly, it is highly

regulated and includes packaging, marking, labeling,

loading, placarding, and a manifest system for tracking

the hazardous waste, especially when transported offinstallation, (including along public highways on the

installation). While some installations operate

RCRA-permitted storage facilities, most Air Force

installations rely on DRMO to provide this service. This

chapter presents a description and explanation of how to

properly complete the paperwork required for turn-in of

hazardous waste to your installation's storage facility. It

also addresses the considerations and requirements for the

transportation of hazardous waste.

5.2. Turn-in. Hazardous waste must be turned in by

large quantity generators and small quantity generators

before the end of the allowed accumulation time limit,

unless a one-time written extension has been granted by

the state authority or regional EPA. All transfers and

turn-ins of hazardous waste to storage facilities must be

conducted under the direction of and processed through

the installation environmental flight. This procedure

prevents unnecessary analyses and handling of the waste,

and provides for an accurate accounting of fund

expenditures. Hazardous waste generating activities are

responsible for ensuring the wastes they generate are

properly characterized, accumulated, stored, and disposed

of in accordance with the base hazardous waste

management plan. The generating activity’s

responsibility for compliance does not end until the

required documentation has been completed and the

physical transfer of the waste to the permitted facility has

been completed. Hazardous waste generating activities

are required to ensure four primary documents are

completed for disposal of hazardous waste: hazardous

waste profile sheet (see Chapter 3), AF Form 2005, DD

Form 1348-1, and the hazardous waste manifest.

5.2.1. Weighing Hazardous Waste. The generating

activity and environmental manager must ensure its

wastes are accurately weighed following established

installation procedures.

5.2.2. Proper Shipping Description. All packaging,

marking, labeling, loading, and placarding is driven by

the DoT proper shipping description found in the

Hazardous Materials Table (49 CFR § 172.101) for each

hazardous waste stream. If the hazardous waste is not

properly identified, serious environmental and financial

consequences could result as the waste is transported and

disposed of. The first place to look for the proper

shipping description is Part II, block 5, of the hazardous

waste profile sheet. See table 4.1 for an explanation on

how to use the Hazardous Materials Table. [49 CFR §

172.200 - 205]

5.2.2.1. The DoT proper shipping description consists of

the following information in this order: the word

"Waste", if not already part of the proper shipping name;

the proper shipping name; hazard class or division; the

UN or NA identification number; and the packing group

(PG I, II, III). Example: “Waste Acetone, 3, UN 1090,

PG II”. [49 CFR § 172.200-205]

5.2.3. AF Form 2005, Issue/Turn-In Request. This Air

Force document begins the actual turn-in process when

the generating activity is ready to dispose of the hazardous

waste. The hazardous waste generating activity completes

AF Form 2005 (see figure 5.2 and table 5.2) then provides
AFPAM 32-7043 1 November 1995 47

it to base supply for further processing. The

environmental manager advises the generating activity on

completion of the above information. Copy 1 of this form

is retained in base supply, and the remaining copies are

given to the generating activity.

5.2.4. DD Form 1348-1, DoD Single Line Item

Release/Receipt Document (Used as Disposal Turn-in

Document). Once base supply receives the AF Form

2005, it will prepare and provide to the generating activity

a DD Form 1348-1 with the information listed in figure

5.3 and table 5.3. The generating activity enters the

date/time in block 13 and prints/signs name in blocks 14

or 15 (original and duplicate) of the disposal turn-in

document. Base supply keeps copy 5 of the completed

form and gives the remaining copies to the generating

activity. Correctly completed samples of disposal turn-in

documents are maintained in the operating records at

DRMO.

5.2.5. Environmental Manager's Certification. The

hazardous waste generating activity delivers the disposal

turn-in document to the environmental manager who

certifies the following: that disposal funds are available;

that the hazardous waste profile sheet and the DD Form

1348-1 are properly completed; and that a hazardous

waste manifest (covered later in this chapter) has been

prepared if the waste must be shipped off-installation. In

no case should the disposal turn-in document be certified

if funds are not available to the environmental manager.

Funds are allocated through accounting and finance office

by either the military interdepartmental purchase request,

or the interfund billing system.

5.2.6. DRMO Acceptance. The generating activity takes

the certified disposal turn-in document to the storage

facility (with the hazardous waste) and retains two copies

for base records after acceptance of the waste by the

operator of the storage facility. The generating activity

retains one copy and returns one copy of the disposal

turn-in document, signed by the storage facility operator,

to the environmental flight. If the storage facility operator

does not accept the waste, the environmental flight must

be immediately notified. The generating activity receives

two copies of the DD Form 1348-1 after DRMO accepts

the waste and signs the DD Form 1348-1. One copy is

retained in the generating activity's hazardous waste file.

The other copy is sent to the environmental flight.

5.3. Transportation. All waste must be properly

packaged, marked, labeled, loaded, placarded (if

required), and manifested before being shipped along any

public highway, on- or off-installation. Actual movement

of the hazardous waste to the disposal pick-up point is the

responsibility of the generating activity. DRMO may

require the installation to retain physical custody of the

waste while DRMO administratively manages disposal or

reclamation of the waste. The generating activity consults

with the base transportation officer and environmental

flight to ensure that all hazardous waste transportation

requirements are met.

5.3.1. Marking for Transportation. Containers with

liquid capacity less than 119 gallons (450 liters), a net

mass less than 882 pounds (400 kg) and maximum

capacity less than 119 gallons for solids, and a water

capacity equal to or less than 1,000 pounds (454 kg) for

gas, are considered non-bulk packaging. Non-bulk

packaging has special EPA and DoT marking

requirements.

5.3.1.1. Markings must be printed in English directly on

the surface of the package or on a label, tag, or sign

securely affixed to the package. The words listed in figure

5.4 must be displayed on all non-bulk packages. They

must be displayed on a background of sharply contrasting

color, must be unobscured, and must be durable.

Markings must also include the proper shipping name,

UN or NA identification number, and name and address

of consignee (receiving agent) or consignor (shipping

agent). This information must match the hazardous waste

manifest. The proper shipping name on the package does

not have to include the word "Waste" if a marking such as

shown in figure 5.4 is used on the package. Many of the

marking requirements can be satisfied by the use of a preprinted marking such as shown in figure 5.5. [40 CFR §

262.32, 49 CFR § 172.301 and 304]

5.3.1.2. If the non-bulk package contains a hazardous

substance (whether a single substance, mixture, or

solution) in its reportable quantity, the letters "RQ" must

be displayed with the proper shipping name, along with

one of the following:

5.3.1.2.1. Technical name of the hazardous substance

from Appendix A to the Hazardous Materials Table;

5.3.1.2.2. The EPA hazardous waste number; or

5.3.1.2.3. The letters "EPA", followed by the appropriate

waste characteristic (ignitability, corrosivity, reactivity, or

Toxicity), or the appropriate "D" number. [49 CFR §

172.324]

5.3.1.3. The technical name, in parentheses, must be

associated with the proper shipping name for all "n.o.s.."

or generic shipping names. [49 CFR Parts 172.203(k)

and 172.301(b)]

5.3.1.4. If the non-bulk package is to be transported by

water, a "Marine Pollutant" mark may be required. [49

CFR § 172.322]

5.3.1.5. Non-bulk combination packages (inner packages

secured by an outer package) containing liquids must be

marked with package orientation arrows on two opposite

sides of the package. [49 CFR § 172.312]

5.3.1.6. Packages containing a poisonous gas (Division

2.3) or a poisonous liquid subject to the "PoisonInhalation Hazard" shipping paper description must be

marked with the words "Inhalation Hazard" in association

with the required labels. Those materials subject to this

provision can be identified by the special provisions,

column 7, of the Hazardous Materials Table. "Poison-
48 AFPAM 32-7043 1 November 1995

Inhalation Hazard" materials have special provision codes

1 to 6 and 13. [49 CFR Parts 172.101, and 172.313]

5.3.1.7. Polychlorinated biphenyls (PCBs) have a special

6" x 6" mark, as shown in figure 5.6, which must be used

on each package and on all four sides of the transport

vehicle. [40 CFR § 761.40 and 761.45]

5.3.2. Labeling. Labels provide warnings to personnel

handling hazardous wastes and emergency responders as

to the potential harms and incompatibilities of individual

packages. Labels, approximately 4" x 4" diamond shaped,

square-on point, provide their warning through color,

pictograms (symbols at top of label), hazard classes or

divisions (numbers at bottom of label), and words in the

center of label. Refer to the Hazardous Materials Table

and 49 CFR 172, Subpart E for more information on

labeling. [40 CFR § 262.31]

5.3.2.1. Labels must be affixed to the package near the

proper shipping name marking. Labels must be affixed to

a background of contrasting color or set off by dotted or

solid line outer borders. The required labels are

prescribed in column 6 of the Hazardous Materials Table

(49 CFR § 172.101). The appropriate hazard class or

division number is displayed in the lower corner of the

primary hazard label only (the primary hazard label is the

first one listed in column 6 and matches the hazard class

or division listed in column 3). Hazard class or division

numbers are not displayed on subsidiary hazard labels

(any other label listed in column 6). Packages which

require more than one label must display those labels

within six inches of each other. [49 CFR Parts

172.101(g), 172.402, and 172.406]

5.3.2.2. When compatible hazardous wastes are placed in

the same outer container, such as an overpack, a label for

each hazard class or division must be shown within six

inches of each other. [49 CFR § 172.404]

5.3.2.3. Combustible liquids in non-bulk packaging are

not required to be labeled. [49 CFR § 172.101(g) and §

172.400]

5.3.3. Loading. Hazardous wastes must be properly and

safely loaded onto vehicles for transportation to facilities

for treatment, storage or disposal. To prevent hazardous

chemical reactions during the transportation, personnel

should follow the "Segregation and Separation Chart of

Hazardous Materials", 49 CFR § 177.848. General

loading safety precautions include the following.

5.3.3.1. All hazardous wastes which are flammable,

compressed gases, corrosives, poisonous, or radioactive

must be secured against movement within the vehicle

during transportation. Containers with valves and other

fittings must be protected to minimize likelihood of

damage and release. [49 CFR § 177.834(a)(g)]

5.3.3.2. Never load hazardous wastes on pole trailers.

[49 CFR § 177.834(b)]

5.3.3.3. Never smoke, and keep fire sources away, while

loading or unloading hazardous wastes containing

explosives, flammable liquids, flammable solids,

oxidizers, or flammable gases. [49 CFR § 177.834(c)(d)]

5.3.3.4. Make sure the vehicle hand brake is set and other

precautions are in place to prevent vehicle movement

before loading or unloading all hazardous wastes. [49

CFR § 177.834(e)]

5.3.3.5. Use tools designed for loading and unloading the

specific type of containers. [49 CFR § 177.834(f)]

5.3.3.6. Cargo tanks must be attended by a qualified

person at all times during loading and unloading. [49

CFR § 177.834(i)]

5.3.3.7. Follow bonding and grounding procedures when

loading flammable liquid wastes into containers or cargo

tanks. [49 CFR § 177.837]

5.3.4. Placarding. Placards are the Department of

Transportation's (DoT) method of aiding emergency

response personnel at a release of hazardous materials

during transportation. Placards are found on freight

containers, tank cars, cargo tanks, and portable tanks. A

placard is a 10 3/4 inch diamond-shaped square-on point.

Placards identify the primary hazards associated with the

contents of the vehicle or container to which they are

affixed. Secondary hazards may not be identified

(exception: materials which present a "Poison-Inhalation

Hazard" must be placarded "Poison" along with primary

hazard; materials which have a secondary hazard of being

dangerous when wet must also carry a "Dangerous When

Wet" placard along with the primary hazard placard.)

Placards may or may not be required, depending on the

specific hazard class/division and/or the quantity

involved. Tables 5.4 and 5.5 outline the general

placarding requirements, but there are several exceptions

to the rules. For example, DoT exempts domestic

shippers of Class 9 materials from having to display the

"Miscellaneous" placard and a "Combustible" placard is

not required for combustible liquids transported in nonbulk packages. [40 CFR § 262.33 and 49 CFR § 172.504]

5.3.4.1. When required, placards are placed on all four

sides of a vehicle (truck, trailer, rail car, van, car).

Portable tanks less than 1,000 gallons and bulk packages

less than 640 cubic feet only require placards on two

opposite sides. Placards provide the following

information: hazard class/division number, UN or NA

identification number (if allowed), hazard color (red,

yellow or green, etc.), and pictogram (symbols for poison,

radioactive, etc.). Placard information must be legible,

visible from the direction it faces, clear of all obstructions,

at least 3 inches away from other markings, and secured

to read horizontally. [49 CFR § 172.512, 172.514, and

172.516]

5.3.4.2. Each installation must ensure the proper placards

are provided to the transporter for each hazardous waste

shipment. Each installation must have a supply of the

appropriate placards on-hand which can be offered to

transporters hauling hazardous waste. It is the
AFPAM 32-7043 1 November 1995 49

transporter's responsibility to replace any placards which

are damaged or lost during transport. [49 CFR § 172.506]

5.3.4.3. The placards in use before HM-181 went into

effect can be used for highway shipments of hazardous

waste until 1 October 2001 (see tables 5.4 and 5.5). [49

CFR § 171.14(c)(2)]

5.3.4.4. Placarding applies to off-installation movements

of hazardous waste including along public highways

located on an installation.

5.3.5. Hazardous Waste Manifest. The hazardous

waste manifest serves three purposes: as a tracking device

to trace shipments of hazardous waste, by identifying who

is responsible for the waste from its point of generation

through ultimate disposal; providing information during

transportation emergencies; and for recordkeeping and

reporting. Information needed for the biennial report is

obtained from the manifest. The hazardous waste

manifest (or state equivalent) can be obtained through

each individual state’s hazardous waste regulatory agency

or through commercial forms suppliers.

5.3.5.1. A hazardous waste manifest is required for all

off-installation shipments of hazardous waste, unless the

installation is classified a conditionally exempt small

quantity generator; or as a small quantity generator and

the waste is reclaimed under a contractual reclamation

agreement. A hazardous waste manifest is required for:

5.3.5.1.1. All hazardous waste transported from off-site

generating activities to an installation's permitted or

interim status TSDF (such as the storage facility operated

by DRMO or the installation itself);

5.3.5.1.2. Hazardous waste shipments from the

installation's permitted or interim status TSDF to an offsite TSDF; and

5.3.5.1.3. Waste shipments within an installation

boundaries requiring travel along public highways on the

installation. [40 CFR § 262.20(a), § 263.10(b), §

263.20(a), and § 260.10]

5.3.5.2. The hazardous waste manifest and continuation

sheet (see figures 5.7 and 5.8) is the shipping document

that identifies the hazardous waste generator,

transporter(s), and TSDF, and describes the contents of

the waste shipment. When a waste shipment leaves the

installation, the manifest must be completed through

block 17 (see tables 5.6 and 5.7), "Transporter 1". One

copy of this "open" manifest must be kept on file at the

installation which generated the waste and the remaining

copies must be provided to the transporter. The "open"

manifest accompanies the transporter to the designated

TSDF. The transporter may also deliver the hazardous

waste to additional transporters who will move the waste

to the designated TSDF, as long as they are identified on

the hazardous waste manifest or continuation sheet. After

acceptance of the waste, the owner or operator of the

TSDF must sign the manifest signifying receipt of the

shipment. This signed (or "closed") manifest is then

returned to the waste generator to complete the paper trail.

If the transporter is unable to deliver the hazardous waste

to the designated TSDF or to an alternate facility

designated on the manifest, the installation must designate

another permitted facility or instruct the transporter to

return the waste. [40 CFR § 262.20 and 263.20]

5.3.5.3. Enough duplicate copies of the manifest should

be completed by the hazardous waste generator in order to

provide the generator, each transporter, and the

designated TSDF with one copy for their records, plus an

additional copy to be returned to the generator. Each

"closed" manifest must be retained by the environmental

flight for at least five years from the date the waste was

accepted by the initial transporter. [40 CFR § 262.22]

5.3.5.4. Many states have adopted their own versions of

the manifest, requiring generators to submit manifest

copies to the state, along with additional information. To

identify the appropriate manifest, determine whether the

installation’s host state and the state to which the

hazardous waste is being sent require the use of a state

manifest.

5.3.5.4.1. If the shipment is being sent to a state

(consignment state) which has a state manifest, it must be

used.

5.3.5.4.2. If the consignment state does not require a state

manifest, but the state where the installation (generator

state) is located has a manifest, it must be used.

5.3.5.4.3. If neither the consignment state nor the

generator's state requires the use of its own state manifest,

then the uniform hazardous waste manifest may be used.

The Air Force prints the uniform hazardous waste

manifest and copies may be obtained from base

publications. [40 CFR § 262.21]

5.3.5.5. The installation commander or designee (DRMO

or environmental manager) has responsibility for

completing and signing the generator section of the

hazardous waste manifest. The generating activity is

responsible for knowing manifesting procedures and

providing support to complete the form. There are three

parts to a hazardous waste manifest. The top portion

identifies the organizations handling the waste, the

middle portion identifies the shipment, and the bottom

portion contains the signatures of the individuals who

handled the waste. [40 CFR § 262.23 and 263.20]

5.3.5.6. After receipt of hazardous waste accompanied by

a hazardous waste manifest, a permitted facility must

accomplish the following.

5.3.5.6.1. Sign and date each copy of the manifest to

certify that the hazardous waste covered by the manifest

was received.

5.3.5.6.2. Immediately give the transporter at least one

copy of the signed manifest.

5.3.5.6.3. Within thirty days after delivery, send a copy of

the manifest to the waste generator.

5.3.5.6.4. Retain at the facility a copy of each manifest

for at least five years from the date of delivery.
50 AFPAM 32-7043 1 November 1995

5.3.5.6.5. Note any significant discrepancies on each copy

of the manifest. [40 CFR § 264/265.71 and 264/265.72]

5.3.6. Emergency Contact and Emergency Response

Information. DoT regulations require hazardous waste

shippers to provide a 24-hour emergency response

telephone number on the manifest for use in the event of

an emergency involving the hazardous waste shipment.

The telephone number must be the number of the person

who is knowledgeable of the hazards and characteristics

of the material being shipped and has comprehensive

emergency response information and accident mitigation

information for that material, or has immediate access to a

person who possesses such knowledge and information.

The telephone number must be monitored at all times the

material is in transport or storage incidental to transport.

A generator could use an installation's emergency

reporting telephone number, as long as the organization

answering the calls is capable of, and responsible for,

providing detailed information concerning the hazardous

waste and has received current emergency response

information on the waste. [49 CFR Part 172, Subpart G]

5.3.7. Notification and Certification Required by the

Land Disposal Restrictions. All hazardous wastes are

subject to land disposal restrictions, as discussed in

Chapter 3. A land disposal restriction notification and/or

certification must accompany the hazardous waste

manifest to notify the disposal facility of the applicable

treatment standards or prohibition levels for California

listed wastes. The notification and/or certification must

include the following information, most of which can be

found on the hazardous waste profile sheet for each waste

stream:

• Manifest number associated with the

shipment of hazardous waste;

• Waste analysis (testing) data or statement of

knowledge as to whether each waste is or is

not restricted;

• EPA hazardous waste number(s) (also known

as waste codes) assigned, listed and

characteristic, contained within the waste

stream;

• Treatment subcategory(s) of the hazardous

waste number(s) (such as "Oxidizer" under

waste code D001);

• Treatability categories ( e.g. wastewater or

non-wastewater); and

• Treatment standard or method of reference

(enter numerical treatment standard or the

five letter treatment code(s) from 40 CFR

268.42, Tables 1, 2, or 3; or CFR section

where the applicable treatment standard(s)

appear in lieu of listing each treatment

standard). [40 CFR § 268.7]

• Exception: All treatment standards must be

listed for each constituent or waste groups in

F001-F005 spent solvents, multi-source

leachate (F039), California listed wastes (40

CFR § 268.32), and for underlying

hazardous constituents in D001 and D002

wastes listed under 40 CFR § 268.37.

5.3.7.1. If the waste can be land disposed without further

treatment, a certification statement listed at 40 CFR §

268.7(a)(2)(ii) must be added to the notification to the

disposal facility. [40 CFR § 268.7(a)(2)(ii)]

5.3.7.2. If a lab pack is being shipped, describe whether it

contains a waste identified in Appendix IV or V to 40

CFR 268. Note: Lab packing for turn-ins to the DRMO

may not be done by the generating activity but may be

done by the DRMO contractor. [40 CFR § 268.42(c) and

40 CFR § 264/265.316]

5.3.7.3. The installation commander, environmental

manager, and DRMO (if applicable) shall coordinate the

completion of a land disposal notification and/or

certification, regardless of whether or not the waste will

be land disposed.

5.3.8. On-Installation Transportation. While there are no

specific RCRA regulations that govern the on-installation

transportation of hazardous waste, it is important to ensure that

any waste transported on-installation is transported in a manner

that will not endanger the health of installation personnel or the

environment. Actual movement of the hazardous waste to the

disposal pick-up point is the responsibility of the generating

activity. Base transportation should be contacted to determine

the exact method and mode of transporting hazardous waste on

base.

5.3.8.1. The generating activity must ensure that containers are

in good condition. Prior to turning in hazardous waste, each

container should be inspected by the generating activity and the

environmental flight to ensure that it is in good condition and

suitable for transportation. The container should have no leaks

and no accumulation of liquid on the top head. Also, there

should be no serious corrosion, dents, sharp creases, or bulging

heads. If the container has a leak or if it is not in good

condition, the waste in the drum must be transferred to a

container in good condition or the container must be overpacked

in a salvage drum. [40 CFR Parts 264/265, Subpart I; 49 CFR §

173.24, 173.24(a), and 177, Subpart B]

5.3.9. Off-Installation Transportation. When transported offinstallation (including along public highways on-installation) the

hazardous waste must be transported by a carrier who has

authorization from the EPA or the State. Drivers must have a

current Commercial Drivers License (CDL). See 49 CFR Part

383. When a generating activity is involved with off-base

movement of hazardous waste, the generating activity must

consult with the base transportation office and environmental

flight to ensure that all DoT, EPA, and OSHA transportation

requirements are met. Installations have the option of

establishing a single office for managing off-base transport of

hazardous waste. They should consider their waste

transportation volume, contracting support, and compliance with

transportation requirements related to health and safety as well

as emergency response (EPA/OSHA/DoT) training. The

following criteria should be considered when selecting a

hazardous waste transporter.

5.3.9.1. Does the company have an EPA identification

number for hazardous waste transportation? Ask the
AFPAM 32-7043 1 November 1995 51

transporter for their identification number, call the state

environmental agency (or EPA Regional office) to validate the

number, and confirm that the number has not been revoked,

terminated, or suspended. Alternatively, you could directly

inquire of your state environmental agency if the company you

are considering has a current EPA Identification Number.

5.3.9.2. Does the transporter have the proper vehicle and/or

equipment to carry the HW? Container shipments typically

require a type of flatbed truck (such as a closed trailer); if the

installation requires hazardous waste to be removed from a tank,

the transporter must be able to provide tank trucks. Evaluate the

condition of the vehicles. Pay particular attention to the

condition of truck tires, brakes, and other obvious safety matters

which can be checked by observation or by simple operation of

the truck. Evaluate the equipment carried by a transporter to

facilitate the loading of the shipment and to respond to spills. A

transporter with a flatbed truck carrying pallet jacks, dollies, and

open head drums with fresh adsorbent and (sparkproof) shovels

and whose truck has a hydraulic lift (if no loading dock is

available) is better prepared and quite likely more capable of

transporting your waste than a transporter with no loading or

spill response equipment. A transporter with a tank truck who

carries a vacuum pump and flexible hosing for evacuating a

storage tank is preferred over one without such equipment.

5.3.9.3. Has the transporter been cited for any violations by

EPA or DoT? Determine if there have been any significant

violations for each potential transporter. The greater the number

and severity of violations, the less the credence to have in a

transporter. Contact both the EPA and DoT. EPA regulates

transporters primarily in areas of manifest documentation and

hazardous waste discharges. Contact the environmental agency

in the state in which the transporter operates (or the regional

EPA if the state does not have RCRA authorization) to identify

any manifest-related violations and citations for inadequately

responding to, reporting, or cleaning up a hazardous waste

discharge.

5.3.9.4. If a transporter only carries hazardous waste within

state boundaries (i.e., intrastate transportation), it is regulated

by the state Department of Transportation in which the

transporter operates. The enforcement branch of the state DoT

primarily conducts and documents roadside inspections. Contact

the state DoT to determine if a hazardous waste carrier has been

found in violation of requirements relating to safety equipment

and motor vehicle safety. The state DoT can also indicate if the

transporter has been granted operating authority by the state,

and if the insurance carrier for the transporter has provided

certification of any state-required motor vehicle insurance.

5.3.9.5. A transporter that crosses state lines (i.e., interstate

transportation) is subject to inspection by both state and Federal

DoT requirements. When the Federal DoT inspects a

transporter, an on-site inspection is conducted, during which

driver log books, vehicle maintenance files, accident report files,

incident (spill) report files, driver qualification files, and the

transporter's driver training program are examined. Copies of

the inspection reports and subsequent violations can be obtained

by writing DoT at the following address: U.S. Department of

Transportation, Attn: Freedom of Information Officer, 400

Seventh and D Street, SW, Washington, DC 20590, (202)

366-0534.

5.3.9.6. Does the transporter have the necessary permits to

carry the waste interstate or intrastate? EPA does not

require a permit for transporters to carry hazardous waste;

however most states have permit requirements.(2) Additionally,

some states require a permit for a vehicle to transport hazardous

waste through their state. Determine if the transporter is

permitted to operate in the state in which it is based by

contacting the state DoT. Determine the route that your

transporter will follow to the TSDF. If the route takes the

transporter outside of the state in which it is based, call each

state DoT to determine if a permit is required for a vehicle to

haul hazardous waste through the state. Ask the transporter in

which states it is permitted to operate to help determine if a

transporter has the authority to carry hazardous waste interstate

and if it is aware of state-specific permitting requirements.

5.3.9.7. Does the transporter have at least the required

minimum amount of insurance? If a transporter is solely

involved in intrastate transportation of small quantities of

hazardous waste (i.e., less than 3,500 gallons), it is subject to

state-specific requirements for insurance. Determine whether or

not a transporter has minimum state-required coverage by

contacting the Department of Transportation for the state in

which the transporter is based. Alternatively, this information

may be obtained by requesting the transporter to furnish you

with a certificate of insurance. If there is any question regarding

the validity of an insurance certification, the company issuing

the certificate (and hence the policy) should be contacted. When

a transporter is involved in interstate transportation of hazardous

waste, it is required to maintain a minimum of $1 million

insurance. A transporter involved in carrying large amounts of

hazardous waste (i.e., 3 3,500 gallons) must maintain at least $5

million insurance, regardless of whether the transporter is

involved in intrastate or interstate commerce. A transporter can

either contract with an insurance carrier or, under certain

conditions, it can self-insure. Federal transportation regulations

require that proof of financial responsibility must be maintained

on-site with the transporter. Therefore, you can verify that a

transporter has adequate insurance by requesting a copy of the

transporter's MCS 90 form (if insured through an insurance

company) or their MCS 82 form (if self-insured).

5.3.9.8. Would current or past customers recommend the

transporter? To gauge the dependability, reliability, and

competence of a transporter prior to contracting their service,

contact past and present customers for their evaluation. Most

transporters will gladly supply a list of customers, although that

list may be biased towards favored customers. An alternate

method to obtain the names and addresses of a transporter's

clients is to obtain the manifest file for the transporter. This

may be done if an on-site audit of the transporter is conducted,

or by contacting the state environmental agency in the state from

which the transporter is based and requesting a copy of the

manifest file for the transporter. Note: although there is no

Federal requirement under RCRA to file manifests with the

appropriate state agency, many states have enacted hazardous

waste management regulations that require the filing of

manifests with the state.

5.3.9.9. What kind of and how much experience does the

transporter have? Searching out past and present customers is

one factor in the equation used to determine the experience of a

hazardous waste transporter. Important to this consideration is

the factoring in of other services that a transporter offers and the

length of time a transporter has been in business. For example,

a transportation firm that also provides emergency remediation

services in the event of a release is an indication that the

transporter can efficiently and effectively handle its own spills.
52 AFPAM 32-7043 1 November 1995

5.3.9.10. How much lead time is required before a shipment

can be carried off-installation? Time plays a crucial role in

the management of hazardous waste. Neither the state nor EPA

will routinely make allowances for waste that remains on-site

past the accumulation time limit (the state may grant a 30-day

extension on a case-by-case basis). Determine the lead time,

i.e., the amount of time required for a transporter to arrive at the

installation after being notified that a shipment is ready. Ensure

that the transporter is capable of reliably responding on the date

required.

5.3.9.11. How much does the service cost? Cost should not be

viewed as the most significant factor in selecting a hazardous

waste transporter and its significance should be weighed in the

light of all other factors discussed above. While hazardous

waste transportation is a competitive industry, a relatively low

price tag may translate into delaying of vehicle maintenance,

reduction of the amount of emergency response equipment

carried on-board, and the employment of marginally qualified

drivers and technical assistance personnel - all of which

decrease the factor of safety with which all transporters must

operate. When evaluating bids for hazardous waste

transportation services, bids that are excessively low by

comparison should be questioned and evaluated cautiously.

5.3.9.12. Lists of transporters authorized to transport hazardous

waste may be obtained from the host state environmental

agency, the regional EPA office; or reference books

commercially available that list hazardous waste transporters.

5.3.9.13. In granting an EPA identification number, the agency

issuing the number is not attesting to the competency or

capability of the transporter, it is only acknowledging that the

company is registered to transport hazardous waste.

5.3.10. When hazardous wastes are shipped out by water or rail,

the installation must follow the requirements of 40 CFR §

262.23 and § 263.20.

5.3.11. Hazardous Waste Imports and Exports. To export

hazardous waste, the installation must follow the requirements

of 40 CFR Part 262, Subpart E. To import hazardous waste, the

installation must follow the requirements of 40 CFR Part 262,

Subpart F.

5.4. TSDF Selection. Although DRMO is the primary

hazardous waste disposal agent for DoD, there are times when

an installation may have to contract for hazardous waste disposal

independent of DRMO. They will follow normal Air Force

procurement requirements for a service contract; but the

selection criteria is extremely critical. Past performance of the

contractor will be a major factor in the selection evaluation

criteria. Each offerer should submit information demonstrating

the following: successful completion of previous similar

contracts; ability to perform the required services including

possession of necessary permits, licenses, certificates of

disposal, and equipment; employment of qualified personnel;

and information on previous violations, fines, or penalties

incurred by the offerer and its major corporate officers. The

following criteria should be considered when selecting a TSDF.

5.4.1. Capability to Treat Wastes. Determining the

appropriate TSDF begins first by knowing the EPA hazardous

waste number for each waste to be shipped and determining

which TSDFs are permitted to accept your hazardous waste.

This determination can be made by writing or telephoning a

TSDF and inquiring if the facility is permitted to receive waste

with the hazardous waste numbers the installation generates.

Request a list of hazardous waste numbers for which the TSDF

is permitted or contact the environmental agency of the state in

which the facility is located, to obtain a list of hazardous wastes

that the facility is permitted to accept.

5.4.1.1. When a hazardous waste manifest is signed, the Base

Commander (or his designee) is certifying that the methods used

by the TSDF to treat or dispose of the waste are the best

available for minimizing the present and future threat of the

hazardous waste to human health and the environment. The

environmental flight (in cooperation with DRMO) should

determine the best treatment or disposal method for each waste.

While some wastes can be rendered non-hazardous by a only

single method, there are a variety of treatment alternatives

available for the majority of hazardous wastes. Evaluating each

method and determining the installation's most practicable

method may turn into a technically challenging, as well as

labor-intensive task. Even though a hazardous waste is

consigned to a TSDF, the waste generator retains legal

responsibility for the waste. If the waste is mismanaged by the

TSDF, EPA or the state can ultimately bring suit against the

generator to remedy the problem (e.g., a generator can be sued

to finance a clean-up action).

5.4.1.2. First consider recycling the waste or sending it to a

TSDF that can recycle or reclaim the hazardous waste. If

recycling or reclamation is not available, consider a facility that

offers a method that is practical and available which achieves

environmentally beneficial reductions of waste toxicity and/or

mobility.

5.4.2. Permit Status. Confirm that the facility is a permitted

or interim status TSDF and verify this with the state or regional

EPA.

5.4.3. History of Violations. Every TSDF must be inspected

by EPA or representatives of the state environmental agency at

least once every two years; Federal and state owned or operated

TSDFs must be inspected at least annually. As a result, there is

a written record, which records each facility's status with respect

to compliance with RCRA. Based on inspections, TSDFs are

cited for violations of the law. The inspection report records are

available to the public and should be reviewed prior to selecting

a TSDF (as well as periodically while using the facility's

services). Inspection reports and notices of violations can be

obtained by submitting a written Freedom of Information Act

request to the Freedom of Information Officer at the state or

regional EPA.

5.4.3.1. When reviewing inspection reports and subsequent

notices of violation, keep in mind that because of the enormity

of hazardous waste management regulations with which a

facility must comply, some paperwork violations that occur on

an infrequent basis may be inevitable. And though excessive

paperwork violations may signal a problem, more serious

violations should be examined and evaluated carefully; serious

violations may indicate serious problems with the facility.

5.4.3.2. A variety of other files available to the public can be

used to help establish reliability and compliance status of a

TSDF. Depending on the agency, there may be a file dedicated

to enforcement actions, legal suits brought against the facility,

and correspondence to and from agency officials, as well as the

facility permit application itself.

5.4.3.3. In addition to the hazardous waste requirements of

RCRA, a TSDF may also have to comply with the requirements

of the Clean Air Act if there are any air emissions from the

facility, the Clean Water Act if it discharges wastewater, and the

Occupational Safety and Health Act's general industry standards.
AFPAM 32-7043 1 November 1995 53

A comprehensive history of compliance identifying all notices of

violation, consent orders and agreements, and levied

administrative, civil, and criminal penalties can be developed by

contacting each state agency that administers the law (e.g., the

state air quality division, state water quality division, and the

state OSHA).

5.4.4. Condition of the Facility. This is best evaluated by

conducting an on-site visit. Typically, TSDFs are happy to

exhibit their storage facilities and structures, analytical

instrumentation, disposal units, and treatment and processing

equipment to present and potential customers. Such visits must

often be scheduled in advance in order to arrange for a

technically competent employee to be available to answer your

questions.

5.4.4.1. When conducting a site visit, take note of the general

housekeeping practices and appearance in the areas where the

waste is off-loaded, stored, processed, treated, and disposed.

Poor housekeeping and appearance may be an indication of poor

or weak management or at the very least, may represent poor

hazardous waste management practices. Look for potential

safety hazards, condition of facilities and equipment, and

availability and use of safety equipment. Be aware of detectable

odors. Your decision to select a TSDF can be strongly

influenced by the degree of order and concern for safety at the

facility. Review the standards for TSDFs in 40 CFR 264 or 265

before the site visit to focus on the necessary requirements.

5.4.5. Liability Insurance. TSDFs are required to maintain

liability insurance either through a carrier or through a

self-insurance program and are also required to maintain

up-to-date financial assurance for closure and post closure care

as part of their Part B permit. Your decision to select a TSDF

should be based partly on the extent of insurance coverage

maintained by the facility, its overall financial status/credit

rating, and the extent to which the contractual arrangements

and their insurance policies will protect the Air Force from

future liability.

5.4.6. Cost. Cost of treatment, storage, or disposal services

must be evaluated but it should not be the only criterion upon

which a TSDF is selected. According to Air Force policy, the

installation Contracting Officer ensures that only qualified

hazardous waste disposal contractors (not just low price bidders)

are awarded contracts. Before the final selection, you should

make an attempt to factor in all considerations presented above.

The Contracting Officer should always consider the enormous

costs associated with remedying the actions of an irresponsible

or less than competent and capable TSDF. A minor savings up

front can easily result in very large expenses later.

5.4.7. When the manifest is signed, the installation commander

(or designee), is certifying that the methods used by the TSDF to

treat or dispose of the waste are the best available for

minimizing the present and future threat of the hazardous waste

to human health and the environment. It is not the goal of EPA

to force each installation to exhaustively search throughout the

country and pay an unreasonable sum of money for any method

of waste treatment, storage, or disposal. EPA allows the

installation the flexibility to reasonably, yet defensibly, select

the most practicable method.

5.4.8. A list of permitted and interim status TSDFs may be

obtained from the state (or regional) environmental agency. The

reference materials discussed in the note of table 5.8 can be

reviewed to determine which facilities offer TSD services. In

addition, during the first quarter of each year, McCoy and

Associates publishes a directory of commercial hazardous waste

management facilities as part of one of the bimonthly issues of

The Hazardous Waste Consultant. This can be obtained from

McCoy and Associates at 13701 West Jewell Avenue, Suite 252,

Lakewood, Colorado 80228.

5.4.9. Pre-Award Survey. A pre-award survey will be

performed for all service contract solicitations, including a site

visit to the proposed treatment or disposal site. Prior to award,

the environmental manager will verify the permits held by the

various treatment and disposal sites. Installations must obtain

MAJCOM approval and justify the need for disposal of

hazardous waste independent of the DRMO.

5.4.10. Quality Assurance. Hazardous waste contracts will be

administered and monitored according to the quality assurance

principles of AFMAN 64-108, Service Contracts. On-site, nonotice follow-up verification audits must be performed at least

annually to verify wastes are handled and disposed of properly,

from cradle-to-grave.

5.5. Forecasting Waste Disposal Requirements. The

environmental manager should program for waste disposal funds

based on the installation's hazardous waste stream inventory and

the most recent contract disposal costs. The most recent contract

disposal costs are available from the DRMO. The

environmental manager ensures that all hazardous waste

disposal is charged against the proper PE (XXX56F) and EEIC

53411 according to AFI 32-7001, Environmental Budgeting.

5.6. Transportation and Disposal Documentation. The

recordkeeping requirements are summarized in table 5.8.

5.6.1. Manifest. Each generating activity, the environmental

flight, and DRMO retain copies of the manifest for five years

after shipment. [40 CFR § 262.23 and § 262.40(a)]

5.6.2. Exception Report. For large quantity generators, if the

environmental manager does not receive a copy of the "closed"

manifest from the designated TSDF within 35 days of the date

the waste was accepted by the initial transporter, action must be

initiated to track its location. If the "closed" manifest has not

been received by the forty-fifth day, an exception report must be

submitted to the EPA Regional Administrator. The report must

include a copy of the manifest and a cover letter describing the

efforts taken to locate the hazardous waste and the results. For

small quantity generators, submit to the EPA Regional

Administrator a copy of the manifest with a note stating that the

manifest has not been received within 60 days of shipment.

Exception reports are maintained for three years after mailed.

[40 CFR § 262.40(c) and § 262.42]

5.6.3. Discrepancy Report. If the TSDF operator detects

significant manifest discrepancies between the quantity or type

of waste designated by the installation on the manifest, the

TSDF operator must contact the generator and transporter by

telephone to reconcile the discrepancy. If the discrepancy is not

resolved within 15 days of the waste being received, the TSDF

operator must submit a report to the EPA Regional

Administrator. The report includes a letter describing the

discrepancy and attempts made to resolve the discrepancy with

the installation, and a copy of the manifest. Significant

discrepancies are variations greater than 10% in weight, batch

variations in the piece count, and any variation between the type

of waste described on the manifest and the type received. [40

CFR § 264/265.72]

5.6.4. Land Disposal Certification. On the land disposal

restriction notification, the generator notifes the TSDF in
54 AFPAM 32-7043 1 November 1995

writing of the appropriate treatment standards and any

applicable prohibition levels. If the installation determines that

the restricted waste can be land disposed without further

treatment, they must submit a notice and a certification to the

TSDF operator in Part 1 of the hazardous waste profile sheet

stating that the waste meets the applicable treatment standards

and prohibition levels. Notices and certifications must be

retained for five years. [40 CFR § 268.7]

5.6.5. Biennial Reports. When hazardous waste is shipped

off-site to TSDFs, or treated on-site, the installation

environmental manager must submit biennial reports (EPA

Form 8700-13A) to the EPA Regional Administrator by

March 1st of each even numbered year. Copies of the

report must be retained on file for three years and include

the following: assigned EPA ID number; report year;

EPA ID numbers, names and addresses of off-site TSDFs

where waste was shipped; names and EPA ID number of

each transporter used; description (EPA hazardous waste

number), DoT class, and quantity of each waste shipped

off-site; description of the waste minimization efforts

taken; description of the changes in volume and toxicity of

waste actually achieved compared to previous years; and

certification signature. Generating activities must assist

the environmental manager in developing this

information through their hazardous waste

documentation. (Note: Installations located in the states

that are authorized to administer and enforce their own

hazardous waste program in lieu of the Federal program

must submit reports to the appropriate state regulatory

agency at the required frequency (may be annual) rather

than to the EPA Administrator.) [40 CFR § 262.40(b)

and § 262.41]

5.7. Air Force Documentation Requirements.

5.7.1. Turn-in Documents. Each AF Form 2005, DD

Form 1348-1, and hazardous waste profile sheet must be

maintained by the generating activity, the environmental

manager, and DRMO when the waste is turned in for

disposal. They must be retained for five years from the

date the waste was last sent for on-installation or off-site

treatment, storage, or disposal.

5.7.2. Certification Letter. A letter identifying

personnel eligible to certify hazardous waste disposal

turn-in documents (DD Form 1348-1), must be on file at

the servicing DRMO.

5.7.3. Purchase Request. The accounting and finance

office obligates hazardous waste disposal funds based on

validated requests from the environmental flight. The

accounting and finance office must maintain records of

the transaction either on AF Form 616, Fund Cite

Authorization, or on the military interdepartmental

purchase request, DD Form 448, Military InterDepartmental Purchase Request, for overseas hazardous

waste transactions.

5.7.4. M-15/GV912 Report. Part IV of the M-15 Report

lists all hazardous waste transfers to the disposal agent

processed by base supply. Each month base supply sends

this report to the environmental manager who compares

the information with the processed turn-in documents and

billing statements. The report is then sent to the

accounting and finance office with any required

adjustments which must be made to the accounting

records. Bioenvironmental engineering services should

also receive a copy of the report.
AFPAM 32-7043 1 November 1995 55

Figure 5.1. Disposal Phase of Hazardous Waste Life-Cycle.
56 AFPAM 32-7043 1 November 1995

Table 5.1. Proper Shipping Description Guidelines.

Hazardous Materials Table (HMT), 49 CFR § 172.101, Subpart B(1)

The basic shipping description has the following components:

Acetone(1), 3(2), UN 1090(3), PG II(4)

(1) Proper Shipping Name

(2) Numerical Hazard Class or Division

(3) UN or NA Identification Number

(4) Packing Group

[49 CFR § 172.202]

Proper Shipping Name

1. Use the hazardous materials description and proper shipping name entry that appears in column 2 of

the Hazardous Materials Table in Roman (bold) type. Italicized entries are not proper shipping

names.

[49 CFR § 172.101(c)]

2. Use the hazardous materials description and proper shipping name in the Hazardous Materials Table,

column 2 (49 CFR § 172.101), that most appropriately describes the hazardous waste. Select the name

in the following order:

First: Technical name

"1,1,1-Trichloroethane, 6.1, UN 2831, PG III"

Second: Generic (family) name

"Alcohol, n.o.s., 3, UN 1987, III" "n.o.s." = "not otherwise specified."

Third: Application, use, or common name (e.g., paint or paint related material)

"Paint, 3, UN 1263, PG II"

Fourth: Generic hazard class

"RQ, Hazardous waste liquid, n.o.s. (Kepone), 9, NA 3082, III"

3. For hazardous wastes, add the word "waste" if not included in the proper shipping name.

"Waste paint, 3, UN 1263, PG II"

[49 CFR § 172.101(c)(9)]

Table continued on next page.
AFPAM 32-7043 1 November 1995 57

Table 5.1. Continued.

4. If the waste is not described on the DoT Hazardous Material Table by name or by its former use, the

waste may be a mixture or solution of a hazardous material and one or more non-hazardous materials.

Look up each waste component in the Hazardous Materials Table. If one or more of the components is

not listed on the table in column 2, the waste is a mixture or solution of a hazardous material and one

or more non-hazardous materials. For combinations of hazardous waste with non-hazardous items

(such as water), select the name from the Hazardous Materials Table for the hazardous component of

the waste and add the words "mixture" or "solution" after the proper shipping name as appropriate.

A mixture is any combination of two or more chemical compounds or elements (solid or liquid).

A solution is a homogenous liquid mixture of two or more chemical compounds or elements that

will not undergo any segregation under conditions normal to transportation (e.g., Hydrochloric

acid mixed with water).

"Waste Hydrochloric acid, solution, 8, UN 1789, II"

[49 CFR § 172.101(c)(10)]

5. Determine if the material meets the description of more than one hazard class by referring to column 3

of the Hazardous Materials Table. For example, a mixture may be both a flammable liquid and toxic,

or a flammable liquid and corrosive. If so, use the hazardous precedence list presented in 49 CFR §

173.2a to select a generic name for the material.

"Alcohols, toxic, n.o.s., 3, UN 1986, I"

"RQ, Waste Flammable Liquids, Corrosive, n.o.s., 3, UN 2924, II (D001, D002)"

[49 CFR § 172.101(c)(12)(iii)]

6. If the waste is a mixture of more than one hazardous material, determine if more than one DoT hazard

class is specified. If not, use the name for the hazard class (see table at 49 CFR § 173.2) of the

mixture as the proper shipping name preceded by the word "Waste" and followed by the letters "n.o.s."

"Waste flammable liquids, n.o.s. (Contains acetone and xylene), 3 UN 1993, II" for a mixture

of acetone and xylene would have a shipping name

[49 CFR § 172.101(c)(12)(iii)]

7. When two or more hazardous materials are mixed in the waste, the proper shipping name is based on

the hazard class(es) of the mixed items. If the mixture has more than one hazard class, use the hazard

precedence prescribed in § 173.2a to select the appropriate hazard class or division, thus the proper

shipping name.

"Flammable liquid, corrosive, n.o.s., 3, UN 2924, II (Contains Methanol, Potassium

hydroxide)"

[49 CFR § 172.101(c)(12)(iii)]

Table continued on next page.
58 AFPAM 32-7043 1 November 1995

Table 5.1. Continued.

8. If a generic name or n.o.s. shipping name is used, the technical name of the hazardous waste must be

entered in (parentheses) in conjunction with the basic description.

"Waste flammable liquid, n.o.s., 3, UN 1993, II (Contains Hexanes)"

"Corrosive liquid, n.o.s., 8, UN 1760, I, (Caprylyl chloride)"

[49 CFR § 172.203(k)(2)]

9. If a hazardous material is a mixture or solution of two or more hazardous materials, the technical

names of at least two components most predominantly contributing to the hazards of the mixture or

solution must be entered in parentheses with the shipping description.

[49 CFR § 172.203(k)(2)]

10. If the technical name of the compound or principle constituent which meets the criteria of Division

6.1, Packing Group I or II is not part of the proper shipping name, then the technical name must be

entered in parentheses.

[49 CFR § 172.203(m)(2)]

Hazard Class/Division

11. Note the numerical hazard class/division associated with the proper shipping name in column 3 of the

Hazardous Materials Table. Ensure the waste meets the criteria of the DoT hazard class/division (see

definitions at 49 CFR § 173.50 through § 173.144). If the hazard class/division is the same, enter the

numerical hazard class/division after the proper shipping name.

[49 CFR § 172.101(d)]

12. If the hazard class or packing group is not the same, check column 1 of the Hazardous Materials Table

to see if there is a plus (+) for one or more of the components of the waste. If a plus (+) is present, the

hazard class cannot be modified. If a plus (+) is not present, you may change the hazard class from

one listed in the Hazardous Materials Table to the hazard class which more accurately defines the

waste.

[49 CFR § 172.101(c)(12)(i)]

UN or NA Identification Number

13. Enter the UN (United Nations) or NA (North American) identification number from column 4 of the

table after the hazard class, preceded by either UN or NA.

[49 CFR § 172.101(e)]

Table continued on next page.
AFPAM 32-7043 1 November 1995 59

Table 5.1. Continued.

Packing Group

14. Enter the packing group, in Roman numerals, from column 5 of the Hazardous Materials Table. The

packing group may be preceded by the letters PG. If more than one packing group is listed, use the

criteria or assigning packing groups found in Subpart D of 49 CFR Part 173.

"Waste Acetone, 3, UN 1090, II" or "Waste Acetone, 3, UN 1090, PG II"

[49 CFR § 172.101(f)]

Additional Information

15. If the quantity in one package equals or exceeds the reportable quantity (RQ) listed in Appendix A to the

Hazardous Materials Table (or when in a mixture or solution, in a concentration by weight which equals

or exceeds the concentration corresponding to the RQ of the material), it is considered a hazardous

substance and must be appropriately identified in the shipping description. Hazardous substances are

regulated by EPA and must be reported when discharged. The following information must be entered, in

parentheses, in association with the basic description:

The name of the hazardous substance as shown in Appendix A to the Hazardous Materials Table;

"RQ, Hazardous waste, solid, n.o.s., 9, NA 3077, III (Lead)"

For hazardous wastes, the EPA hazardous waste number;

"RQ, Hazardous waste, solid, n.o.s., 9, NA 3077, III (D008)"

For hazardous waste which exhibit EPA characteristics of ignitability; corrosivity; reactivity, or

toxicity, the letters "EPA" followed by the word "ignitability", "corrosivity", "reactivity", or

"toxicity", as appropriate or the corresponding "D" number;

"Hazardous waste, liquid, n.o.s., 9, NA 3082, III, RQ (EPA Toxicity)"

and

the letters "RQ" must be entered before or after the basic shipping description.

"RQ, Allyl alcohol, 6.1, UN 1098, I, Poison-Inhalation Hazard, Zone B"

"Environmentally hazardous substance, solid, n.o.s., 9, UN 3077, III, RQ (Adipic acid)"

Appendix A to the Hazardous Materials Table also contains reportable quantities for listed specific

source and non-specific source waste numbers and for hazardous wastes which have the characteristics

of ignitability, corrosivity, reactivity, and TCLP toxicity. If the hazardous waste is not a hazardous

substance due to specific chemical components, it may still be a hazardous substance due to its EPA

hazardous waste number.

[49 CFR § 172.101(c)(8) and § 172.203(c)]

Table continued on next page.
60 AFPAM 32-7043 1 November 1995

Table 5.1. Continued.

16. If a hazardous waste meets the definition of Division 6.1, Packing Group I or II, and the fact that it is a

poison is not disclosed in the shipping name or class entry, the word "Poison" shall be associated with the

shipping description.

"Waste Phenol solution, 6.1, UN 2821, II, Poison"

[49 CFR § 172.203(m)(1)]

17. If a material is poisonous by inhalation, the words "Poison-Inhalation Hazard" and the words "Zone A",

"Zone B", "Zone C'", or "Zone D" for gases or "Zone A" or Zone B" for liquids, as appropriate, shall be

entered on the shipping paper immediately following the shipping description.

"RQ, Allyl alcohol, 6.1, UN 1098, I, Poison-Inhalation Hazard, Zone B"

Hazard zones can be identified under codes 1 through 6, and 13 under the Special Provisions section,

column 7 of the Hazardous Materials Table.

[49 CFR § 172.203(m)(3), § 173.116(a), and § 173.133(a)]

18. When non-bulk packages are being shipped by water, the words "Marine Pollutant" must appear in

association with the basic description for materials which are a marine pollutant. Marine pollutants are

listed in Appendix B to the Hazardous Materials Table.

"RQ, Waste Mercury compounds, liquid, n.o.s., 6.1, UN 2025, I, Poison, Marine Pollutant,

(D009)"

[49 CFR § 172.203(l)]

1. If the hazardous waste was turned in with a national stock number, the Hazardous Material Information

System may list the proper shipping name, hazard class, and identification number, if the information on the

pure material has been updated to reflect HM-181 requirements.
AFPAM 32-7043 1 November 1995 61

Figure 5.2. Sample Air Force Form 2005, Issue/Turn-In Request.
62 AFPAM 32-7043 1 November 1995

Table 5.2. AF Form 2005, Issue/Turn-In Request Instructions.

Blocks Information Required

1-3 Enter the letters "TIN".

8-11 Enter the parent Federal stock class which produced the waste.

 9150 Petroleum, oils, lubricants

 8010 Paints, waste paint related material

 6350 Antifreeze, windshield washer fluid

6850 Solvents

5950 Transformers

9999 Spill Residue

12-14 Enter the letters "PHW".

15-18 Enter the EPA hazardous waste number (D001, F001, P068, etc).

19-22 Enter the contract line item number; usually same as Federal stock class.

23-24 Enter the unit of issue (quantity - GL or LB) for contract line item number.

25-29 Enter the quantity of waste going to disposal (50 = 00050).

30 Enter the activity code "R".

31-35 Enter the generating activity's organization and shop code.

36-39 Enter the Julian date.

40-43 Enter the next serial number from the organization's control register.

44 Enter the material condition code; use the letter "H".

62 Enter the action taken code; enter the number "9".

A Identify the generating activity manager's name, organization, telephone number, and

date.

D Write the words "Hazardous Waste" to readily identify to base supply. If a hazardous

waste profile sheet is not required for turn-in (i.e., it is not a newly generated waste),

enter the DRMO assigned waste profile reference number.

F Identify the cost of disposal, and unit of issue from the applicable disposal contract.

Example: $1.23/GL

J Enter proper shipping description (see table 5.1 for further information).

Example: Waste naphtha, petroleum, 3, UN 1255, II

AF Form 2005 is taken to base supply which will input data to generate DD Form 1348-1.
AFPAM 32-7043 1 November 1995 63

Figure 5.3. Sample DD Form 1348-1, DoD Single Line Item Release/Receipt Document (Used as Disposal Turn-In

Document).
64 AFPAM 32-7043 1 November 1995

Table 5.3. DD Form 1348-1, Disposal Turn-In Document Instructions.

Block Information Required

8-11 The Federal stock class

15-18 The EPA hazardous waste number

30-43 The 14-position document number which includes the 6-position DoD Activity Address Code (DODAAC) for base

supply, 4 position Julian date, and 4-position serial number in columns 30-43

51 The letter "A" under Signal

52-53 The appropriate fund code from DoD 4000.25-7-S1

74-80 The unit acquisition cost

A Installation’s address (usually environmental flight) and EPA or state identification number

B DRMO's address and EPA or state identification number

C The notation "HW"

D The hazardous waste number and Federal stock class

I Actual weight of the container and contents

T The quantity within the specific type of container

U Proper DoT shipping description

V Reportable Quantity (RQ) in lbs (kgs)

W Base supply individual's signature in block W

X Waste stream description: For non-national stock number hazardous waste items, enter the word "Waste" and the

item's proper shipping name as shown in 49 CFR Part 172. Attach additional documentation, such as the hazardous

waste profile sheet or the material safety data sheet for the hazardous material(s) which generates the waste. For

national stock number hazardous waste items, enter the word "Waste" and the item's proper shipping name as found

in the Hazardous Materials Information System.

Y DoT packaging citation: When hazardous waste is turned in in its original package, the generating activity must

certify as to the true condition and reliability of the containers. This block must have one of the following

statements: "Packaged in accordance with DoT 49 CFR 170-189", or "Packaging equals/exceeds DoT 49 CFR

170-189".

AA The DRMO assigned waste profile reference number on file for subsequent turn-ins of the same waste stream

FF The contract line item number in block FF

FF Total cost of disposal in block FF (computation is contract line item number unit cost times the turn-in quantity)

GG Total cost of disposal in block GG (computation is contract line item number unit cost times the turn-in quantity)

12 The 6-position bill to DODAAC if other than base supply DODAAC

13 Generating activity enters date/time

14 Generating activity's representative prints name

15 Generating activity's representative signs name
AFPAM 32-7043 1 November 1995 65

Figure 5.4. Required EPA Marking for Containers of 110 Gallons or Less.

"HAZARDOUS WASTE--Federal Law Prohibits Improper Disposal. If found, contact the nearest police or

public safety authority or the U.S. Environmental Protection Agency.

Generator's Name and Address

Manifest Document Number"

Figure 5.5. Sample of Preprinted Marking Which Can Be Used to Meet EPA/DoT Requirements.

HAZARDOUS WASTE

FEDERAL LAW PROHIBITS IMPROPER DISPOSAL

If found, contact the nearest police or public safety authority or the U.S.

Environmental Protection Agency.

Proper DoT UN or

Shipping Name ______________________________________________ NA No

_______

Generator __________________________________________________

Address ____________________________________________________

City _______________________________________________________ State

_________

Manifest Accumulation

Document No ________________________________________________Start Date

_____

EPA ID No ______________________________ EPA Hazardous Waste No

______

HAZARDOUS WASTE

FEDERAL LAW PROHIBITS IMPROPER DISPOSAL
66 AFPAM 32-7043 1 November 1995

Figure 5.6. Sample PCB Marking.

CAUTION

CONTAINS

PCBs

(Polychlorinated Biphenyls)

A toxic environmental contaminant requiring

special handling and disposal in accordance with

U.S. Environmental Protection Agency Regulation:

40 CFR 761 -- For Disposal Information contact

the nearest U.S. E.P.A. Office.

_______________________________________

In case of accident or spill, call toll free the U.S.

Coast Guard National Response Center:

800-424-8802

Also Contact

Tel. No.

Table 5.4. Placarding Requirements for Table 1 Hazardous Materials.

Table 1 - Placarding Requirements

Placard Any Quantity On A Transport Vehicle

· In addition to placard specified, any transport vehicle, bulk package, or freight container that contains a material subject to the

"Poison-Inhalation Hazard" shipping paper description must be placarded with either the "Poison" or "Poison Gas" placard,

as appropriate. There is no need to duplicate these placards if they are required already.

Hazard Class HM-181 Placard Pre HM-181 Placard

1.1 EXPLOSIVE 1.1 EXPLOSIVE A

1.2 EXPLOSIVE 1.2 EXPLOSIVE A

1.3 EXPLOSIVE 1.3 EXPLOSIVE B

2.3 POISON GAS POISON GAS

4.3 DANGEROUS WHEN WET FLAMMABLE SOLID (W)

6.1

(PG I, INHALATION HAZARD)

POISON POISON

7 - (RADIOACTIVE

YELLOW III LABEL)

RADIOACTIVE RADIOACTIVE
AFPAM 32-7043 1 November 1995 67

Table 5.5. Placarding Requirements for Table 2 Hazardous Materials.

Table 2 - Placarding Requirements

1,001/5,000 lb (454/2268 kg) Rule

• A transport vehicle or freight container which contains less than 1,001 lbs (454 kg) aggregate gross weight of

hazardous materials listed below is not required to be placarded.

• A freight container, unit load device, transport vehicle or rail car which contains non-bulk packages with two or

more categories of hazardous materials that require different placards listed below may be placarded

"DANGEROUS" instead of individual placards. When 5,000 lbs (2,268 kg) or more of one of the hazard classes

are loaded at one facility, the placard listed below for the hazard class is required.

• In addition to placard specified, any transport vehicle, bulk package, or freight container that contains a material

subject to the "Poison-Inhalation Hazard" shipping paper description must be placarded with either the "Poison"

or "Poison Gas" placard, as appropriate. There is no need to duplicate these placards if they are required already.

Hazard Class HM-181 Placard Pre HM-181 Placard

1.4 EXPLOSIVE 1.4 DANGEROUS

1.5 EXPLOSIVE 1.5 BLASTING AGENT

1.6 EXPLOSIVE 1.6 DANGEROUS

2.1 FLAMMABLE GAS FLAMMABLE GAS

2.2 NON-FLAMMABLE GAS NON-FLAMMABLE GAS

3 FLAMMABLE FLAMMABLE

COMBUSTIBLE LIQUID(1) COMBUSTIBLE COMBUSTIBLE

4.1 FLAMMABLE SOLID FLAMMABLE SOLID

4.2 SPONTANEOUSLY

COMBUSTIBLE

FLAMMABLE SOLID

5.1 OXIDIZER OXIDIZER

5.2 ORGANIC PEROXIDE ORGANIC PEROXIDE

6.1 - PACKING GROUP I OR II,

OTHER THAN PG I

INHALATION HAZARD

POISON POISON

6.1 - PACKING GROUP III KEEP AWAY FROM FOOD NONE

6.2 NONE NONE

8 CORROSIVE CORROSIVE

9

(2) MISCELLANEOUS NONE

ORM-D NONE NONE

Note 1. Combustible liquids in non-bulk packaging are not required to be placarded.

Note 2. The Class 9 placard is not required for domestic transportation.
68 AFPAM 32-7043 1 November 1995

Figure 5.7. Sample Uniform Hazardous Waste Manifest.
AFPAM 32-7043 1 November 1995 69

Figure 5.8. Sample Uniform Hazardous Waste Manifest Continuation Sheet.
70 AFPAM 32-7043 1 November 1995

Table 5.6. Hazardous Waste Manifest Instructions.

Item Title Instructions

1 Generator's U.S. EPA ID number and Manifest

Document Number

Enter the installation's unique 12-digit EPA identification number.

Immediately following the EPA ID number, enter a unique five-digit

number which assigned to this manifest (number each shipment

consecutively or use the Julian date which corresponds to the shipment

date).

2 Page 1 of _____ Enter the total number of pages used. Continuation sheets must be

used if more than four waste types are being shipped to the same TSDF

on the same shipment or if more than two transporters are used.

3 Generator's Name and Mailing Address Enter the name and mailing address of the installation's organization

that will manage the returned manifest forms (normally the

environmental manager).

4 Generator's Phone Number Enter the phone number of an authorized organization on-base that can

be reached in the event of an emergency, twenty-four hours a day while

the shipment is in transit. * See Emergency Communication

Requirements.(2)

5 Transporter 1 (Company Name) Enter the company name of the first transporter who will transport the

waste off-installation.

6 U.S. EPA ID Number for Transporter 1 Enter the U.S. EPA twelve digit identification number of the first

transporter identified in Item 5.

7 Transporter 2 (Company Name) If a second transporter will be used to transport the waste to the

designated TSDF enter the name of the second transporter. If more

than two transporters are used, the additional transporters must be

listed on the continuation sheet. Every transporter used between the

installation and the designated facility must be listed.

8 U.S. EPA ID Number for Transporter 2 If a second transporter will be used, enter the second transporter's U.S.

EPA identification number.

9 Designated Facility Name and Site Address Enter the company name and the site address of the facility you have

designated to receive the hazardous waste listed on the manifest. The

address must be the site address and cannot be a post office box or

rural route number.

10 U.S. EPA Identification Number for

Designated Facility

Enter the U.S. EPA twelve-digit number of the designated facility

identified in item 9.

11 U.S. DoT Proper Shipping Name, Hazard

Class, and ID Number, and Packing Group

(HM-181 change)

Enter the best and most descriptive DoT proper shipping name, hazard

class, UN or NA identification number, and packing group. This

information should be listed on the hazardous waste profile sheet for

the waste stream. Review the Hazardous Materials Table and the

appendix to the Hazardous Materials Table in 49 CFR 172 to ensure

the proper shipping name is correct. Use the continuation sheet if

space for additional waste descriptions is needed. * See Emergency

Communication Requirements.(2)

12 Number and Type of Containers Enter the number and type of containers for each waste.

Abbreviation Type of Container Abbreviation Type of Container

DM Metal drums, barrels, kegs DT Dump trucks

DW Wooden drums, barrels, kegs CY Cylinders

DF Fiberboard or plastic drums, barrels, keg CM Metal boxes, cartons, cases , and roll-offs

Table continued on next page.
AFPAM 32-7043 1 November 1995 71

Table 5.6. Continued.

Abbreviation Type of Container Abbreviation Type of Container

TP Portable tanks CW Wooden boxes, cartons, cases

TT Cargo tanks (tank trucks) CF Fiber or plastic boxes, cartons, case

TC Tank cars BA Burlap, cloth, paper, or plastic bags

Item Title Instructions

13 Total Quantity Enter the total quantity, excluding the weight of the packaging, of

waste described on each line.

14 Unit of Measure Enter the appropriate unit of measure (either by weight or by volume)

for each waste listed in item 13. G = Gallons (liquids only); P =

Pounds; T = Tons (2000 pounds); Y = Cubic Yards; L = Liters

(liquids only); K= Kilograms; M = Metric tons (1000 kilograms); and

N = Cubic Meters

15 Special Handling Instructions If the installation is exporting the hazardous waste, the city and state

where wastes will depart from the United States must be entered in this

block. This block may be used to indicate special transportation,

treatment, storage, or disposal information or bill of lading information.

For example, the waste characterization or profile number assigned to

your waste by the designated TSDF can be entered in this space. The

space may also be used to designate an alternate TSDF to which the

waste should be transported if the primary designated facility is unable

to receive the waste. * See Emergency Communication

Requirements(2)

16 Generator's Certification The generator must read, sign by hand, and date the certification

statement. When the manifest is signed, the person signing it is legally

certifying the following: the shipment is fully and accurately described

on the manifest; the containers are in proper condition for

transportation; a waste minimization program is in place at the

installation; and the method of treatment, storage, or disposal is the best

available to the installation. The Base Commander or their designee

has primary responsibility for signing the manifest as the generator.

The designee should be the servicing DRMO or the installation

environmental manager. Where DRMO is not the Base Commander's

designee, DRMO will co-sign all manifests for shipments of hazardous

waste on Defense Logistics Agency accountable records.

If a mode of transportation other than highway is being used, cross out

the word "highway" in the certification and insert the appropriate mode

of transportation, such as rail, water, or air. If rail, water, or air

transportation of your waste will occur in addition to highway

transportation, add the words "and rail," or "and water," or "and air"

after the word "highway" in the certification. If the installation is

exporting the hazardous waste, add at the end of the first sentence of the

certification the following words: "and conforms to the terms of the

EPA Acknowledgement of Consent to this shipment."

Table continued on next page.
72 AFPAM 32-7043 1 November 1995

Table 5.6. Continued.

Item Title Instructions

17 Transporter 1 (Acknowledgement of Receipt

of Materials)

The first transporter must print or type the name of the person

accepting the waste, sign, and date the manifest to acknowledge

receipt of a shipment. Obtain the hand written signature of the

first transporter before the waste is shipped off-installation

and retain this copy of the open manifest. Transporters must

then deliver the waste to the next designated transporter (if

indicated in item 7), the designated facility (as indicated in item

9), an alternate facility designated by the installation, or a

designated place outside the United States if the installation is

exporting the waste.

18 Transporter 2 (Acknowledgement of Receipt

of Materials)

If more than one transporter is used, the second transporter must

print or type the name of the person accepting the waste, sign, and

date the manifest to acknowledge receipt of a shipment from the

first transporter.

19 Discrepancy Indication Space The designated TSDF or alternate designated facility must note in

this space any significant discrepancies between the quantity or

type of waste described on the manifest and the quantity or type of

waste actually received at the facility. Significant discrepancies in

quantity are, for bulk wastes, variations greater than ten percent

by weight. A variation in piece count is considered to be a

significant discrepancy for waste delivered in containers. For

example, one missing or extra drum in a truckload is a significant

discrepancy.

Significant discrepancies pertaining to the type of waste would be

obvious differences, discovered by the TSDF, between the type of

waste described on the manifest and the type of waste actually

received. For example, waste solvent substituted for waste acid or

toxic constituents not reported on the manifest are significant

discrepancies.

20 Facility Owner or Operator Certification of

Receipt of Hazardous Materials Covered by

this Manifest Except as Noted in Item 19

The owner, operator, or authorized representative of the TSDF

must print or type and sign his or her name, and enter the date. By

signing the manifest, the TSDF acknowledges that the waste has

been received and accepted, except for any discrepancies noted in

item 19. The TSDF must retain a copy of the manifest and, within

30 days of delivery, send a copy of the closed manifest to the

generator.

A

(1) State Manifest Document Number This is usually a preprinted number on state manifests. Carry over

to continuation sheets.

B

(1) State Generator's ID Enter if state ID number is different than U.S. EPA ID number.

C

(1) State Transporter's ID Enter state certified hauler number and driver certification number

(if required by state).

D

(1) Transporter's Phone Enter number where authorized agent can be contacted during an

emergency.

E

(1) State Transporter's ID Enter state certified hauler number and driver certification number

(if required by state).

F

(1) Transporter's Phone Enter number where authorized agent can be contacted during an

emergency.

G

(1) State Facility's ID Enter state ID number.

Table continued on next page.
AFPAM 32-7043 1 November 1995 73

Table 5.6. Continued.

Item Title Instructions

H

(1) Facility's Phone Enter number where authorized agent can be contacted during an

emergency.

I

(1) Waste Number Enter EPA hazardous waste number.

J

(1) Additional Description for Materials Listed

Above

Enter EPA hazardous code (I/C/R/E/H/T), physical state (solid-S;

liquid-L; gas-G; sludge-SL), specific gravity; and estimated

percentage of each waste constituent.

K

(1) Handling Codes for Wastes Listed Above Enter code for how waste will be handled (landfill-L; incineration,

heat recovery, burning-B; chemical or physical treatment-T; reuse

or recycling-R; and storage-S).

Note 1: Items A through K (shaded area) are not required by the Federal regulations. However, many states may require the waste

generator or the TSDF to complete some or all of this information. The instructions listed above are typical of the state requirements but

state environmental authorities should be contacted to specific requirements have been identified.

Note 2: Emergency Communication Requirements. Emergency response telephone numbers must be entered on a manifest either

immediately following descriptions in item 11, in item 4, or in another clearly visible location if the number is for all wastes listed on the

manifest and the manifest indicates that the number is for emergency response information. For example, the notation "EMERGENCY

CONTACT: (555) 555-1234", is an appropriate way to identify the emergency response telephone number on a manifest.

DoT regulations also require additional emergency response information to be included on the manifest or attached to the manifest. The

manifest must include, as a minimum, the following information: hazardous materials description; immediate hazards to health; risks of

fire or explosion; immediate precautions to be taken in the event of an accident or incident; immediate methods for handling small or large

fires; initial methods for handling spills or leaks in the absence of fire; preliminary first aid measures; and 24-hour manned emergency

response telephone number. Transporters must keep the information easily accessible during transportation. A reference for each waste

stream to the appropriate guide page in the DoT Emergency Response Guidebook in Section 15 of the manifest will satisfy this requirement

if the transporter maintains a copy of the Guidebook in the vehicle at all times.

The following burden disclosure statement must be included with each uniform hazardous waste manifest, either on the form, in the

instructions to the form, or accompanying the form:

"Public reporting burden for this collection of information is estimated to average 37 minutes for generators, 15 minutes for

transporters, and 10 minutes for treatment, storage, and disposal facilities. This includes time for reviewing instructions, gathering

data, and completing and reviewing the form. Send comments regarding the burden estimate, including suggestions for reducing

the burden to: Chief, Information Policy Branch, PM-223, U.S. Environmental Protection Agency, 401 M Street SW,

Washington, DC 20460; and to the Office of Information and Regulatory Affairs, Office of Management and the Budget,

Washington, DC 20503."
74 AFPAM 32-7043 1 November 1995

Table 5.7. Hazardous Waste Manifest (Continuation Sheet) Instructions.

Item Title Corresponding Instructions

From Manifest

21 Generator's U.S. EPA ID Number and Manifest Document Number 1

22 Page of 2

23 Generator's Name 3

24, 26 Transporter(s) Company Name(s) and Order (enter the sequential order of

that transporter after the word "Transporter")

5, 7

25, 27 Transporter(s) U.S. EPA ID Number(s) 6, 8

28 U.S. DoT Shipping Description 11

29 Number and Type of Containers 12

30 Total Quantity 13

31 Unit of Measure 14

32 Special Handling Instructions 15

33, 34 Transporter(s) Acknowledgment of Receipt of Materials 17, 18

35 Discrepancy Indication Space 19

L -T Not required by EPA Check state requirements

Continuation sheets must be used if either of the following apply: more than two transporters are used to transport the waste or more space

is needed for additional US DoT descriptions and related information because more than four different wastes are being shipped. Most of

the same information required on the manifest is also required on the continuation sheet to the manifest.
AFPAM 32-7043 1 November 1995 75

Table 5.8. RCRA Records and Corresponding Minimum Retention Periods.

Record or File Retention Time Citation

Hazardous waste

determination documentation

5 years from the date that the waste

was last sent to a treatment, storage,

or disposal facility†

40 CFR 268.7(a)(7)

Annual report 3 years from the due date of the

report†

40 CFR 262.41

Hazardous waste manifest 5 years from the day the waste was

accepted by the initial transporter†

40 CFR 262.20

Accumulation site inspection

logs

3 years from the date the inspection

was conducted†

40 CFR 262.34

40 CFR 265.15(d)

40 CFR 265.174

Exception reports 3 years from the due date of the

report†

40 CFR 262.42

Land disposal restriction

notice & certification

5 years from the date the waste was

last sent to a TSDF†

40 CFR 268.7

Notification of intent to export

waste

3 years from the date the hazardous

waste was accepted by the initial

transporter†

40 CFR 262.53

EPA acknowledgement of

consent

(for exports)

3 years from the date the hazardous

waste was accepted by the initial

transporter†

40 CFR 262.51

40 CFR 262.53

Waste export confirmation of

delivery

3 years from the date the hazardous

waste was accepted by the initial

transporter†

40 CFR 262.54

Annual report (required of

primary exporters of hazardous

waste)

3 years from the date the hazardous

waste was accepted by the initial

transporter†

40 CFR 262.56

Employee training records Current personnel: until closure of

facility; former personnel: 3 years

from date the individual last worked

at facility

40 CFR 262.34

40 CFR 265.16

† The periods of retention are extended automatically during the course of any unresolved

enforcement action or as requested by EPA.
76 AFPAM 32-7043 1 November 1995
AFPAM 32-7043 1 November 1995 77
78 AFPAM 32-7043 1 November 1995
AFPAM 32-7043 1 November 1995 79
80 AFPAM 32-7043 1 November 1995

___________________________________________________________________________________________________________________________

Chapter 6

EMERGENCY PROCEDURES AND PREVENTION

6.1. Overview. Throughout the life-cycle of the

hazardous waste, caution must be taken to manage and

operate hazardous waste in a way that protects human

health and minimizes the possibility of a fire, explosion,

or release into the environment. AF installations must

develop written emergency response procedures for all

hazardous waste generation and storage locations and

incorporate these contingency plan requirements into the

installation's hazardous materials (HAZMAT) emergency

planning and response plan (called the HAZMAT Plan),

described in Air Force Pamphlet, AFPAM 32-4013,

Hazardous Material Emergency Planning and Response

Guide. The installation's HAZMAT Planning Team and

Response Team play integral roles in the development of

the HAZMAT Plan to cover all hazardous waste

contingencies. They can assist generating activities in

developing their site-specific requirements.

6.2. Preparedness Requirements. Accumulation sites

and permitted facilities must be equipped with the

following: a communication system to summon

emergency assistance (telephone or radio); an internal

communication or alarm system to alert personnel who

can be affected during an emergency; fire suppression

equipment (fire extinguishers, fire extinguishing system,

an adequate water supply, etc.); spill control equipment;

and decontamination equipment. The type and amount of

equipment depends upon the activities being conducted,

characteristics of the stored hazardous waste, type of

storage facility and surrounding terrain, human and

environmental exposures, and capabilities of emergency

responders. [40 CFR Part 264.32 & 265.32; 264.34 &

265.34]

6.2.1. Initial Accumulation Points. Generating

activities should maintain communication and alarm

systems, fire and spill control equipment, an emergency

shower, and an emergency eyewash near their initial

accumulation points. The HAZMAT Planning Team can

assist generating activities, accumulation site managers,

and permitted storage facilities in identifying their

equipment requirements and incorporating its use in sitespecific procedures.

6.2.2. Equipment Testing. All required emergency

equipment must be tested and maintained to ensure its

reliability during an incident. A periodic inspection

schedule should be established and all inspections

documented. [40 CFR Part 264.33 & 265.33]

6.3. Response Requirements.

6.3.1. Local Authorities. Most Air Force installations

possess the capabilities to provide on-installation response

to emergencies resulting from hazardous waste spills,

fires, or explosions. However, situations may arise where

the services of off-installation agencies or organizations

may also be required. Arrangements must be made to

familiarize police, fire departments, and emergency

response teams both on- and off-base with the following

information:

• Layout of the installation;

• Properties of hazardous waste handled at the

installation and associated hazards;

• Places where installation personnel would normally

be working;

• Entrances to roads inside the installation; and

• Possible evacuation routes. [40 CFR Part

264.37(a)(1) & 265.37(a)(1)]

6.3.1.1. Where more than one police and fire department

or hazardous materials team might respond to an

emergency, installations must establish agreements

designating primary emergency authority to a specific

agency and agreements with any others to provide support

to the primary. Written agreements with state emergency

response teams, emergency response contractors, and

equipment suppliers should be established if any of them

would be called upon to assist in installation emergency

incident response efforts. [40 CFR Part 264.37(a)(2)(3) &

265.37(a)(2)(3)]

6.3.1.2. Arrangements for all agreements are made by the

installation commander or his designee. All

arrangements made are to be documented. In cases where

state or local authorities decline to enter into an

agreement to support emergency operations involving

hazardous waste, the refusal must also be documented.

[40 CFR Part 264.37(b) & 265.37(b)]

6.3.1.3. Provide each agency or organization with a copy

of the installation HAZMAT plan. For documentation,

retain a copy of the cover letter submitted with each

contingency plan. Document familiarization visits by

having each visitor sign a log. [40 CFR Part 264.53(b) &

265.53(b)]

6.3.1.4. Medical personnel must be familiar with the

properties of the hazardous wastes. The installation

bioenvironmental engineering services should assist in

determining potential types of injuries or illnesses and the

effects of overexposure. Aeromedical Services personnel

will assist in determining the emergency first aid

procedures for each hazardous waste listed.

Arrangements must be made to familiarize local hospitals
AFPAM 32-7043 1 November 1995 81

with the properties of hazardous waste handled at the

facility and the types of injuries or illnesses which could

result from fires, explosions, or releases from your

installation. [40 CFR Part 264.37(a)(4) & 265.37(a)(4)]

6.4. Incorporation of Requirements into Installation's

HAZMAT Plan.

6.4.1. HAZMAT Plan -- Contingency Plan

Requirements. To minimize hazards to human health or

the environment, detailed written emergency procedures

must be developed for the handling of hazardous waste

emergencies (fire, explosion, or release). Permitted

facilities and large quantity generators must incorporate

the procedures into a contingency plan. All procedures

and plans must incorporate the requirements of 29 CFR

Part 1910.120, Hazardous Waste Operations and

Emergency Response, paragraphs (p) and (q); and The

Emergency Planning and Community Right-to-Know Act

of 1986. [40 CFR 262.34(a)(4), 264.51, & 265.51]

6.4.1.1. Small quantity generators must develop

emergency response procedures only. Permitted facilities,

such as a storage facility operated by DRMO, have a

contingency plan incorporated into their Part B permit.

[40 CFR 262.34(d)(5) & 270.14(7)]

6.4.1.2. The contingency plan need not be a separate

document. AFI 32-4002 establishes the requirement to

incorporate written procedures and contingency plans into

the installation's HAZMAT Plan. Specific planning

requirements are listed in AFPAM 32-4013, Hazardous

Materials Emergency Planning and Response Guide. The

HAZMAT Plan must include the following contingency

plan requirements: current listing of emergency

coordinators (Incident Commanders or On-Scene

Commanders who will manage the emergency incident);

arrangements to coordinate activities amongst all on- and

off-base emergency responders (command, control and

coordination); a thorough description of available

emergency equipment; and an evacuation plan and

procedures for accumulation site or storage facility

personnel. [40 CFR Part 264.52 & 265.52]

6.4.2. HAZMAT Plan - Review & Update. AF

Installations must ensure the HAZMAT Plan is kept

current and reflects changes within the installation

impacting the plan. Some potential changes requiring

Plan amendment include the following:

• Any changes to RCRA standards or applicable state

requirements which impact the plan;

• The plan fails in the event of an emergency;

• Any installation changes that increase the potential

for fires, explosions, or releases of hazardous waste

or changes in the response requirements;

• The list of emergency coordinators changes; or

• The list of equipment necessary to respond to

emergencies changes. [40 CFR Part 264.54 &

265.54]

6.4.2.1. All organizations and activities on- and off-base

must receive a copy of the current HAZMAT Plan. [40

CFR Part 264.53 & 265.53]

6.4.2.2. The HAZMAT Plan is implemented whenever

there is an emergency which involves hazardous waste.

[40 CFR Part 264.51 & 265.51]

6.5. Emergency Coordinator Responsibilities. The

Incident Commander (IC) or On-Scene Commander

(OSC), designated as the RCRA emergency coordinator,

oversees all response actions and ensures the proper

notifications are made to outside agencies.

Responsibilities include the following: [40 CFR Part

262.34(d)(5)(i)(iv), 264.55 & 265.55]

6.5.1. Ensures all personnel within the immediate hazard

area have been notified and have taken appropriate

actions according to the HAZMAT Plan. [40 CFR Part

264.56(a)(1) & 40 CFR 265.56(a)(1)]

6.5.2. Immediately notifies those emergency response

organizations with designated response roles. [40 CFR

Part 262.34(d)(5)(iv)(A), 264.56(a)(2) & 40 CFR

265.56(a)(2)]

6.5.3. Immediately notifies affected local emergency

planning committees (LEPC) and state emergency

response commission (SERC) if the release will go or has

gone off the installation. [40 CFR Part 355.40(b)]

6.5.4. Conducts a thorough site assessment (size up) of

the situation to ensure all hazardous waste involved and

their hazards have been properly identified using visual

clues, data sources, and monitoring, as required. [40 CFR

Part 264.56(b)(c) & 40 CFR 265.56(b)(c)]

6.5.5. Develops an incident action plan to control the

situation based on the requirements of the HAZMAT Plan

and 29 CFR 1910.120, Hazardous Waste Operations and

Emergency Response, paragraph (q). [40 CFR Part

262.34(d)(5)(iv)(B), 264.56(e) & 40 CFR 265.56(e)]

6.5.6. Ensures evacuation of installation personnel within

the hazard area. If evacuation beyond the installation is

required, notifies the local authorities immediately and

coordinates their response actions with the installation's.

The National Response Center (NRC) must also be

immediately notified at (800) 424-8802. [40 CFR

262.34(d)(5)(iv)(C), Part 264.56(d)(1) & 40 CFR

265.56(d)(1)]

6.5.7. Ensures hazardous waste operations or processes

which were abandoned or stopped do not create further

hazard during the emergency. [40 CFR Part 264.56(f) &

40 CFR 265.56(f)]

6.5.8. Controls run-off of any fire fighting agents used.

Holds run-off until analyzed. If analysis proves

hazardous, takes appropriate action in accordance with

local, state, and Federal authorities. [40 CFR Part

262.34(d)(5)(iv)(B), 264.56(g) & 40 CFR 265.56(g)]

6.5.9. After the emergency phase, ensures all recovery

and remediation activities are conducted in accordance

with local, state, and Federal authorities. All corrective
82 AFPAM 32-7043 1 November 1995

actions involving clean-up operations at sites covered by

RCRA must be conducted according to 29 CFR 1910.120,

Hazardous Waste Operations and Emergency Response,

paragraphs (b) through (o). [29 CFR Part 1910.120(a), 40

CFR Part 262.34(d)(5)(iv)(B), 264.56(g) & 40 CFR

265.56(g)]

6.5.10. Ensures hazardous waste operations or processes

which are incompatible with the released hazardous waste

are not initiated until clean-up is completed and

emergency equipment is ready for use. [40 CFR Part

264.56(h) & 40 CFR 265.56(h)]

6.5.11. Ensures appropriate notification to the EPA

Regional Administrator, and state and local authorities

that the hazardous waste facility is back into compliance

before operations are resumed. Ensures documentation of

the incident is properly annotated in facility operating

records and that a written report is submitted to the EPA

Regional administrator within fifteen (15) days. [40 CFR

Part 264.56(i)(j) & 40 CFR 265.56(i)(j)]

6.6. Toxic Chemical Release Reporting (EPA Form R).

Executive Order 12586 requires all Federal agencies to

establish guidelines to comply with the requirements of

the Emergency Planning and Community Right-to-Know

Act (EPCRA) of 1986, also known as Title III of the

Superfund Amendments and Reauthorization Act

(SARA). Under Section 313 of EPCRA, installations

must annually report the amount of hazardous wastes

accidentally or routinely released into the environment

and the amount contained in wastes transferred off-site.

[40 CFR Part 372]

6.7. Release Reporting and Emergency Notification

(Incident Report). There are numerous Federal, state,

and local laws which require verbal notification and

written reports. A written report must be submitted to the

EPA Regional Administrator within 15 days of the

incident. In addition, all hazardous waste releases must

be reported and documented according to AFI 32-4002,

chapter 4. [40 CFR § 264/265.56(j)]
AFPAM 32-7043 1 November 1995 83

Federal Requirements Summary

Large Quantity (LQ); Small Quantity (SQ); Conditionally Exempt Small Quantity (CEQ); Permitted Storage Facility (PSF)

Element Standard LQ SQ CEQ PSF

General Inspection Requirements 40 CFR Part 262.34

 40 CFR Part 264/265.174

 40 CFR Part 264/265.195

Personnel Training 40 CFR Part 262(d)(5)(iii)

 40 CFR Part 264/265.16

 29 CFR Part 1910.38(a)(5)

 29 CFR Part 1910.120

Preparedness and Prevention:

Facility Maintenance and Operation

Required Equipment

Equipment Testing and Maintenance

Communications or Alarm System

Required Aisle Space

Arrangements with Local Authorities

 40 CFR Part 262.34(d)(4)

 40 CFR Part 264/265.31

 40 CFR Part 264/265.32

 40 CFR Part 264/265.33

 40 CFR Part 264/265.34

 40 CFR Part 264/265.35

 40 CFR Part 264/265.37

Contingency Plan:

Purpose and Implementation

Content

Copies

Amendments

 40 CFR Parts 264 or 265

 40 CFR Part 264/265.51

 40 CFR Part 264/265.52

 40 CFR Part 264/265.53

 40 CFR Part 264/265.54

Emergency Coordinator 40 CFR Part 262.34(d)(5)(i)

 40 CFR Part 264/265.55

Emergency Procedures 40 CFR Part 262.34(d)(5)(iv)

 40 CFR Part 264/265.56

 40 CFR Part 264/265.196

 29 CFR Part 1910.38

 29 CFR Part 1910.120(p) & (q)

Table continued on next page.
84 AFPAM 32-7043 1 November 1995

Federal Requirements Summary

Large Quantity (LQ); Small Quantity (SQ); Conditionally Exempt Small Quantity (CEQ); Permitted Storage Facility (PSF)

Element Standard LQ SQ CEQ PSF

Recovery and Remediation 40 CFR Part 262.34(d)(5)(iv)(B)

 40 CFR Part 264/265.56

 40 CFR Part 264/265.196

 29 CFR Part 1910.120

Reporting 40 CFR Part 262.34

 40 CFR Part 264/265.56

 40 CFR Part 264/265.196(d)

 40 CFR Part 355.40(b)

Toxic Chemical Release Reporting (EPA Form R) 40 CFR Part 372

Operations at TSDFs:

Safety and Health Program

Hazard Communication Program

Medical Surveillance Program

Decontamination Program

New Technology Program

Material Handling Program

Training Program

Emergency Response Program

* (see Notes and Exceptions)

 29 CFR Part 1910.120(p)

 29 CFR Part 1910.120(p)(1)

 29 CFR Part 1910.120(p)(2)

 29 CFR Part 1910.120(p)(3)

 29 CFR Part 1910.120(p)(4)

 29 CFR Part 1910.120(p)(5)

 29 CFR Part 1910.120(p)(6)

 29 CFR Part 1910.120(p)(7)

 29 CFR Part 1910.120(p)(8)

 29 CFR Part 1910.120(a)(2)(iii) * * *

__________________________________________________________________________________________________________________________

Chapter 7

PERSONNEL SAFETY

7.1. Overview. Basic health and safety issues must be

recognized and followed whenever and wherever

hazardous wastes are present. This chapter discusses

some of the hazards posed by hazardous waste and how to

protect yourself and fellow co-workers.

7.2. Typical Hazards and Harms. Hazardous wastes

are characterized as being ignitable (gases, liquids, or

oxidizers which burn easily), corrosive (mainly acids or

bases), reactive (explode easily, react violently with water,

or generate toxic gases at low or high pH), or toxic.

Hazardous wastes present a multitude of chemical and

physical hazards which can harm personnel who come in

contact or are exposed. If personnel become aware of

these hazards through training and follow the proper

procedures when handling hazardous wastes, the chance

of harm to themselves, other personnel, property, and the

environment is reduced dramatically. There are several

ways for hazardous wastes to create harm: thermal (heat,

heat of reaction, and cold); radiation; asphyxiation (lack

of oxygen); corrosive (action by acid or base); contact

(chemical burns or dermatitis); etiologic (biologic

exposure, such as medical infectious waste); mechanical

(direct physical contact with container, slipping, falling,

sharp objects); and toxic (poisonous) effects. Many of

these hazards cannot be seen or are not obvious, so

personnel must know the physical and chemical

characteristics of the hazardous wastes, especially the

exposure symptoms and emergency first aid treatment.

7.2.1. Exposure Routes. Workers may be exposed to

hazardous chemicals and wastes through contact,

inhalation, absorption, ingestion, and injection. While the
AFPAM 32-7043 1 November 1995 85

following paragraphs briefly describe these exposure

routes, more detailed information and the specific hazards

from your wastes may be obtained from the installation

bioenvironmental services.

7.2.1.1. Contact with the skin, eyes, and mucous

membranes is the most common way in which chemicals

damage humans. Some wastes, such as acids and bases,

may cause burns; some may remove the skin’s natural

oils; others may cause rashes. Protective clothing, gloves,

and eye protection are critical for workers handling

hazardous materials and wastes which pose contact

hazards.

7.2.1.2. Inhalation is one the most important routes of

exposure. Not only can chemicals damage the respiratory

system, but also they can be transferred to the bloodstream

and eventually damage or accumulate in other parts of the

body. Respiratory protection is critical for workers

handling hazardous chemicals and wastes which pose an

inhalation hazard.

7.2.1.3. While the skin usually acts as a very effective

barrier, some chemicals can be absorbed through the skin.

Warmth and moisture increase the penetration rate

through the skin. Sweating opens the skin pores.

Inflamed skin and hair follicles also speed the absorption

process. Skin protection is critical for workers handling

hazardous wastes which pose an absorption hazard.

7.2.1.4. Ingestion of a hazardous waste is less common

than the other routes of exposure, but can be a problem

when proper precautions are not taken. Protective

clothing will protect a person from ingesting a hazardous

waste if splashed. Because of the potential for hand-tomouth transfer, eating, drinking, smoking, and applying

cosmetics should be prohibited until personnel have been

decontaminated, removed their protective clothing, and

washed accordingly.

7.2.1.5. Injection is the least common form of entry, but

can be one of the most hazardous. Puncture wounds from

sharp objects allow hazardous waste toxins to directly

enter the blood stream. Breaks in the skin can serve as

avenues for injections of toxins into the blood stream.

Personnel must be aware of surroundings which contain

physical hazards and protect themselves accordingly with

the proper protective clothing and procedures.

7.2.2. Toxic Health Effects. Health effects can vary

greatly based on the type of exposure and the person being

exposed. A person can receive an acute exposure,

resulting from a single incident. Or exposure can be

chronic, resulting from repeated doses over a period of

time. Exposure effects can be localized, affecting only the

tissue with which it came in contact. Or the exposure

effect can be systemic, traveling through the body to affect

certain body organs or systems. Exposure effects can also

be a combination of the above. Exposure reactions are

also based on time. An acute reaction has an adverse

health effect immediately, with symptoms developing

rapidly. A chronic reaction is an adverse health effect

with symptoms that develop slowly or recur frequently due

to the exposure. To help determine how toxic a hazardous

waste is to humans, personnel should become familiar

with the toxicological terms and exposure values, such as

permissible exposure limit (PEL), threshold limit valuetime weighted average (TLV-TWA), occupational

exposure limit (OEL), and others. The terms are included

in the glossary in attachment 2. The installation

bioenvironmental engineering services can provide further

information and training in these terms and values.

7.3. How to Protect Yourself and Co-Workers. Before

personnel become involved with hazardous wastes, they

must be appropriately trained to understand the hazardous

wastes with which they will come in contact, their

potential hazards and harms, exposure symptoms and

emergency first aid treatment, the appropriate engineering

controls and steps to operate, the appropriate personal

protective clothing and equipment required to perform the

various types of hazardous waste activities, and the

specific procedures for each activity in which they take

part. They must then follow these requirements to the

letter and ensure their co-workers do the same.

7.3.1. Protective Equipment. Hazardous waste work

areas should be equipped with the appropriate engineering

controls to reduce and maintain personnel exposure below

published acceptable limits, thus minimizing the potential

harm and hazards of hazardous wastes. When

engineering controls are impractical, personal protective

equipment may be required. Personal protective

equipment includes respiratory and skin protection to

protect the worker against chemical (corrosive, toxic, or

etiologic) and physical harms (thermal, asphyxiation, or

mechanical). Personal protective equipment must be

properly selected to fit the potential harms, the task, the

environment (work areas), and the worker. OSHA

Standards 29 CFR Part 1910, Subpart I, AFOSH

Standards 127-31 and 48-1, and bioenvironmental

engineering services must be consulted on the proper

selection of personal protective equipment.

7.3.1.1. When a written personal protective equipment

program is required it should address the following:

selection based upon site hazards; use and limitations of

the equipment; work mission duration; maintenance and

storage; decontamination and disposal; training and

proper fitting; donning and doffing procedures; inspection

procedures prior to, during, and after use; evaluation of

the effectiveness of the personal protective equipment

program; and limitations during temperature extremes,

heat stress, and other appropriate medical considerations.

When elements, such as donning and doffing procedures,

are provided by the manufacturer of a piece of equipment

and are attached to the plan, they need not be rewritten

into the plan as long as they adequately address the

procedure or element. [29 CFR Part 1910.120 (g)(5) and

(p)(1)]
86 AFPAM 32-7043 1 November 1995

7.4. Safe Working Procedures. All initial accumulation

points, accumulation sites, and permitted facilities must

develop site-specific procedures for the handling of

hazardous waste. These procedures should cover normal

day-to-day, non-routine, and emergency activities. The

fire protection flight, ground safety, environmental

management, and bioenvironmental engineering services

should be consulted for specific site requirements. The

HAZMAT Planning Team should review all emergency

procedures to ensure they are compatible with the

HAZMAT Plan protocols. [40 CFR Part 262.34(a)(4) and

(d)(5)(iii) & 264/265, Subpart D]

7.4.1. Container Safety. Container and tank management is a

critical safety issue. If the hazardous waste is not released from

its container or tank, personnel will not be exposed to the harms

of the hazardous waste. Procedures must be developed to ensure

the following: hazardous waste is only placed in containers or

tanks in good condition; the containers or tanks are compatible

with the hazardous waste; the handling of containers minimizes

the risk of a release; containers are kept closed during storage;

and daily (tanks) or weekly (containers) inspections are

conducted. [40 CFR Part 264.17 & 265.17; 40 CFR Part

264/265 Subparts I & J]

7.4.2. Explosion Safety. To reduce the potential for fires

or explosions, all hazardous waste which presents an

ignitability hazard must be handled according to

flammable and combustible liquids requirements cited in

29 CFR Part 1910.106, National Fire Protection

Association's Flammable and Combustible Liquids Code

(NFPA Standard 30), and AFOSH Standard 127-43. [40

CFR Part 264.17(a) & 265.17(a)]

7.4.2.1. One common problem with hazardous waste is

the mixing of incompatible wastes, leading to violent

reactions, container or tank failures with release of

hazardous waste, toxic or flammable gas clouds, fires, or

explosions. Situations created by incompatible waste

mixing pose extreme danger to site personnel, emergency

responders, the public, and the environment.

Incompatible wastes and materials must be kept separate

at all times through proper procedures and engineering

controls. AFOSH Standard 127-68, Chemical Safety, and

the Handbook of Chemical Hazard Analysis Procedures

(FEMA/DoT/EPA, 1989) can be used to determine the

compatibility of hazardous wastes. Material safety data

sheets for the materials which generate the hazardous

waste should be reviewed for incompatible mixtures and

unsuitable containers. The bioenvironmental engineering

services, the environmental manager, and fire protection

flight should be consulted when there is an uncertainty

about mixing or container compatibilities of any

hazardous wastes. [40 CFR Parts 264.17(b), 264.172,

264.177, Appendix V & 265.17(b), 265.172, 265.177,

Appendix V]

7.4.3. Changes to Hazardous Waste Process. Before

any hazardous waste disposal process or activity is

modified, or a new process or activity is planned, the

environmental manager, bioenvironmental engineering

services, and HAZMAT Planning Team should be

consulted.

7.4.4. Permitted Facility Requirements. Permitted and

interim status facilities have additional requirements

established by 29 CFR Part 1910.120, Hazardous Waste

Operations and Emergency Response, paragraph (p).

Requirements include programs in safety and health,

hazard communication, medical surveillance,

decontamination, new technology, material handling,

training, and emergency response. The emergency

response paragraph (p)(8) also applies to large quantity

and small quantity generators. Conditionally exempt

generators who will not involve their personnel in the

emergency response must only comply with 29 CFR Part

1910.38, Emergency Action Plans.

7.4.5. Contamination Avoidance and Decontamination.

There must be procedures to minimize worker contact

with hazardous wastes or with equipment that has

contacted hazardous wastes. [29 CFR Part 1910.120(k)

and (p)(4)]

7.5. Additional Sources of Information. There are

multiple sources for information concerning hazardous

waste, including Federal, state, and local regulations, Air

Force publications, and national consensus standards. Air

Force Occupational Safety and Health Standards provide

an excellent source of information for identifying and

complying with health and safety requirements. Many of

the AFOSH Standards were developed to help the Air

Force implement specific OSHA regulations. State and

local environmental authorities can assist in determining

installation specific requirements. Each installation

maintains a staff of technical specialists (fire, safety,

military public health, bioenvironmental engineering

services, and environmental management) who are there

to assist all generating activities in meeting and

maintaining compliance.

7.6. Applicable AFOSH Standards:

7.6.1. AFOSH Standard 91-31, Protective Clothing and

Other Equipment.

7.6.2. AFOSH Standard 91-32, Emergency Shower and

Eyewash Units.

7.6.3. AFOSH Standard 91-43, Flammable and

Combustible Liquids.

7.6.4. AFOSH Standard 91-56, Fire Protection and

Prevention.

7.6.5. AFOSH Standard 91-68, Chemical Safety.

7.6.6. AFOSH Standard 48-1, Respiratory Protection

Program.

7.6.7. AFOSH Standard 48-8, Controlling Exposures to

Hazardous Materials.

7.6.8. AFOSH Standard 48-21, Hazard Communication.
AFPAM 32-7043 1 November 1995 87

Federal Requirements Summary

Large Quantity (LQ); Small Quantity (SQ); Conditionally Exempt Small Quantity (CEQ); Permitted Storage Facility (PSF)

Element Standard LQ SQ CEQ PSF

Ignitable, Reactive, or Incompatible Wastes 40 CFR Part 264/265.17

 29 CFR Part 1910.120

Use and Management of Containers:

Condition of Containers

Compatibility of Waste with

Container

Management of Containers

Inspections

Containment

Incompatible Wastes

Examples

Aisle Space

 40 CFR Part 264/265 Subpart I

 40 CFR Part 264/265.171

 40 CFR Part 264/265.172

 40 CFR Part 264/265.173

 40 CFR Part 264/265.174

 40 CFR Part 264.175

 40 CFR Part 264/265.177

 40 CFR Part 264/265 Appendix V

 40 CFR Part 264/265.35

Tank Systems:

General Operating

Requirements

Inspections

Ignitable or Reactive Wastes

Incompatible Wastes

Special Requirements

 40 CFR Part 264/265 Subpart J

 40 CFR Part 264/265.194

 40 CFR Part 264/265.195

 40 CFR Part 264/265.198

 40 CFR Part 264/265.199

 40 CFR Part 265.201(e)

____________________________________________________________________________________________________

Chapter 8

TRAINING

8.1. Overview. All personnel involved in handling

hazardous waste must be trained in proper waste

management procedures to include all EPA, OSHA, and

DOT requirements. OSHA training requirements for

hazardous waste operations and emergency response can

be found in AFI 32-4002, Hazardous Materials

Emergency Planning and Response Compliance. [40

CFR 262.34(a)(4) and (d)(5)(iii), 264/265.16, 29 CFR

1910.120(q), 29 CFR 1910.1200(h)(2), Subpart H of 49

CFR Part 172, and 49 CFR 177.816]

8.2. Personnel Requiring Training. All Air Force

personnel whose jobs entail working with hazardous waste

(handle, monitor, or dispose of) must be properly trained

prior to performing any tasks involving hazardous waste.

This includes, but is not limited to, persons who perform

the following: decide which wastes are hazardous waste;

complete hazardous waste manifests, annual reports, or

exception reports; fill hazardous waste containers or

tanks; remove hazardous waste from accumulation tanks

or containers; transport hazardous wastes to or from

storage and treatment units and disposal facilities;

transport hazardous waste to or from accumulation sites;

perform hazardous waste clean-up (non-emergency

response); inspect hazardous waste accumulation sites,

storage, treatment, or disposal facilities; operate

accumulation sites; work at permitted or interim status

TSDFs; collect hazardous waste samples; and conduct

other hazardous waste related activities as designated by

installation commanders or their environmental

managers.
88 AFPAM 32-7043 1 November 1995

8.3. Training Frequency. All such personnel must

successfully complete initial and annual refresher

hazardous waste training. All supervisors of personnel

performing hazardous waste activities must successfully

complete hazardous waste management training before

they supervise hazardous waste operations.

8.4. Who Conducts Training. The environmental

management office is responsible for ensuring hazardous

waste management training is accomplished. All Air

Force hazardous waste management training instructors

must be properly trained. Training sources may include

the Air Force Training program (see below), the Air Force

Institute of Technology, the Air Force School of

Aerospace Medicine, or commercial sources.

8.5. Air Force Training Programs. There are two

general components to the training required by RCRA and

OSHA: how to perform duties in a way that ensures the

facility's compliance with all regulations and how to

respond to emergencies involving hazardous waste. The

Air Force has developed a slide presentation and an

interactive (computer-based) training program to help

meet Federal hazardous waste training requirements. The

programs are geared to flightline, maintenance, and other

AF personnel who generate and transport hazardous

waste. To fully comply with all regulations, both

programs must be tailored to meet each installation's

specific requirements. Unique procedures for waste

determination, accumulation, transportation, and turn-in,

must be incorporated into the training program, along

with an installation's specific emergency response

procedures. All hazardous waste training must cover, at

minimum, the training elements listed in Table 8.1., to

include the most current Federal, state, and local

requirements.

8.6. Customizing Training. Each training course

offering must be customized to fit the specific hazardous

waste management requirements of the attendees.

Arrange training for similar activities at the same time.

For example, present one course offering for installation

activities that generate hazardous waste as a result of

painting operations (e.g., the civil engineers paint shop,

aircraft painting operations, missile maintenance, etc.);

another offering for activities that generate hazardous

waste from cleaning and degreasing operations (e.g.,

transportation, aircraft maintenance, etc.),

and another for operators of the hazardous waste storage

facility.

8.6.1. Administrative Personnel. Some personnel are

involved in hazardous waste management from an

administrative perspective only, such as bioenvironmental

engineering services technicians who collect samples for

analytical analysis, public affairs personnel who field

requests for information, the installation commander who

signs the hazardous waste manifests, and the judge

advocates who are involved in permit applications.

Provide specific training which allows them to conduct

their responsibilities in a manner which complies with the

regulations.

8.6.2. Emergency Responders. Some personnel are only

involved with hazardous waste when they respond to

emergencies, such as the fire department, the disaster

response group, the HAZMAT Response Team, and other

emergency responders. The training requirements for

emergency responders can be found in AFI 32-4002,

Hazardous Materials Emergency Planning and Response

Compliance.

8.6.3. Hazardous Waste Training Matrix. Table 8.2

provides a matrix identifying which sections of the Air

Force Hazardous Waste Management (slide) Training

program and the Interactive (computer-based) Training

for Hazardous Waste Management program to help

customize training for specific organizations or functions.

8.7. Hazard Communication Training. Although 29

CFR Part 1910.1200, Hazard Communication Standard,

does not specifically apply to hazardous waste, the DoD

Federal Hazard Communication Program (AFOSHTD

161-21-1W and AFOSHTD 161-21-1G) can be used to

help train personnel in the hazards, harms, general

precautions and procedures for hazardous wastes.

8.8. Training Documentation. Training records must

document previous training received, type of present

training, date, instructor, test score, and projected date of

refresher training. Training records must be maintained

as long as the individual is associated with, or for three

years after the individual is no longer working with,

hazardous waste. There are two methods for documenting

training. Individual supervisors must use AF Form 1098,

Special Task Certification and Recurring Training, or the

installation hazardous waste instructor may also maintain

the hazardous waste centralized records. [40 CFR

264/265(d) & (e)]
AFPAM 32-7043 1 November 1995 89

Table 8.1. Hazardous Waste Training Requirements.

Hazardous Waste Training Elements

This table identifies the minimum hazardous waste training elements to meet EPA, OSHA, and Air Force requirements. Installation-specific

information, listed below the elements as bullets, should be added to ensure that the training program meets state and local regulatory

requirements. Installation-specific information which must be added is presented in italic letters.

Section I: Introduction to the Resource Conservation and Recovery Act:

• Add names and telephone phone extensions of installation personnel who can be contacted for additional

information regarding the installations' hazardous waste management plan.

Section II: Hazardous Waste Characterization:

• Typical characteristic and listed hazardous wastes generated on-base

• Photos of installation activities that generate HW

Section III: Container Management:

• How should empty containers be managed and where should they be taken

• Location of the Hazardous Materials Table

• How to obtain containers for hazardous waste accumulation

• Installation-specific container marking requirements, beyond those required by EPA and DOT

Section IV: Hazardous Waste Accumulation Management:

• Locations of on-base accumulation points and satellite accumulation points together with a designation of

each point's accumulation point manager and wastes accepted

• Installation procedures for setting up new accumulation points and satellite accumulation points

• How to obtain and replenish emergency equipment and other supplies for accumulation point.

• Installation waste segregation procedures, such as drum color coding, labeling, etc.

• Accumulation point inspection and record keeping responsibilities; identify who must conduct weekly

inspections (daily inspections for tanks) and where records of inspections and training are maintained

Table continued on next page.
90 AFPAM 32-7043 1 November 1995

Table 8.1. Continued.

Section V: Hazardous Waste Disposal:

• Local procedures for turn-in

• Procedures for on-installation transportation of hazardous waste in containers or tanks from satellite

accumulation points to accumulation points and from accumulation points to permitted storage

facilities; identify if on-base transportation is accomplished by the organization that generates waste,

the Transportation Squadron, or others

• Procedures for requesting waste analyses

Section VI: Hazardous Waste Manifesting and Transportation:

• Proper packaging for shipping

• Where manifests may be obtained at your facility

• Who completes, coordinates, approves, and signs hazardous waste manifests

• Where manifest records are maintained

• Telephone number for reporting releases to the Installation Command Post

Section VII: Emergency Procedures and Prevention:

• Procedures for reporting releases, spills, fires, and explosions

• Location and availability of the contingency requirements in HAZMAT Plan

• Telephone numbers and/or other means for contacting Emergency Coordinator, and Command Post

• Locations where emergency response and decontamination equipment is stored

• Specific procedures and roles on how to respond to releases, spills, fires, and explosions involving the

hazardous wastes generated at the installation

• Local prevention program

Section VIII: Personnel Safety and Training:

• Hazard warning labels that may be used on containers or tanks bearing hazardous chemicals at the

installation

• Who should be contacted for specific information on the physical properties or health and safety

aspects of hazardous chemicals

• Location and availability of reference materials (e.g. the Hazardous Materials Information System,

material safety data sheets, handbooks, etc.) which can be used to obtain safety information

• Identify the personal protective equipment which must be worn when working with specific types of

hazardous waste generated at the installation

Section IX: Waste Minimization:

• Installation's waste minimization program

Section X: Record Keeping and Reporting Requirements:

• State and local reporting and record keeping requirements

• Procedures for installation record keeping
AFPAM 32-7043 1 November 1995 91

Table 8.2. Hazardous Waste Training Matrix.

Section

Organization/Functio

n

I II III IV V VI VII VIII IX X

Accumulation Point

Managers

Generating Activities

Emergency Response

Personnel

Hazardous Waste

Contract

Administration

Personnel

Bioenvironmental

Engineering

Technician

Judge Advocate

General

Transportation

Environmental

Management

Flight

Quality Assurance

Evaluator

Base Supply

Ground Safety

Air Force Hazardous Waste Management

Training Program

• Section I - Introduction to Resource

Conservation and Recovery Act

• Section II - Identification of Hazardous

Wastes

• Section III - Container Use, Marking, and

Labeling

• Section IV - Accumulation Site

Management

• Section V - Waste Turn-In Procedures

• Section VI - Manifesting and Transportation

of Hazardous Waste

• Section VII - Spill Prevention and Response

to Emergencies

• Section VIII - Waste Minimization

• Section IX - Personnel Safety

Interactive Training for Hazardous Waste

Management

• Section I - Introduction

• Section II - Characterization of Hazardous

Waste

• Section III - Container Management

• Section IV - Waste Accumulation

Management

• Section V - Waste Turn-In Procedures

• Section VI - Transporting Hazardous Waste

• Section VII - Emergency Procedures and

Preparedness

• Section VIII - Pollution Prevention

• Section IX - Personnel Safety

• Section X - Reports and Record Keeping
92 AFPAM 32-7043 1 November 1995

Federal Requirements Summary

Large Quantity (LQ); Small Quantity (SQ); Conditionally Exempt Small Quantity (CEQ); Permitted Storage Facility (PSF)

Element Standard LQ SQ CEQ PSF

Personnel Training:

Hazardous Waste

Emergency Action Plans

TSDF Emergency Response

* (see Notes and Exceptions)

Installation Emergency Response

Transportation

 40 CFR Part 262.34(d)(5)(iii)

 40 CFR Part 264/265.16

 29 CFR Part 1910.38

 29 CFR Part 1910.120(p)(7) & (8)

 29 CFR Part 1910.120(a)(2)(iii)

 29 CFR Part 1910.120(q)(6)

 49 CFR Parts 172.701, 702, 704

 49 CFR Part 177.816

* *

 *

Training Records 29 CFR § 1910.120(p)(8)(iii)

 29 CFR § 1910.120(q)(6)

 40 CFR § 264/265.16(d) & (e)

___________________________________________________________________________________________________________________________

Chapter 9

WASTE MINIMIZATION

9.1. Overview. Reducing generation of hazardous waste

to a minimum is an important objective of pollution

prevention. Pollution prevention is a departure from years

of end-of-the-pipe waste management practices. It

establishes a cradle-to-grave approach to waste

management. It 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 problem. The goal of pollution

prevention is to establish a long-term downward trend in

the volume of wastes generated and contaminants and

pollutants released to the environment. By achieving this

goal, the costs resulting from reactionary waste

management practices and dependence on hazardous

materials use will also be greatly reduced.

9.2. Air Force Pollution Prevention Program. The Air

Force has developed a proactive pollution prevention

policy which calls for the reduction of hazardous material

use and releases of pollutants into the environment to as

near zero as feasible. All Air Force installations are

required to prepare a Pollution Prevention Management

Plan which accomplishes the following:

• Establishes reduction baselines for the following six

areas: the EPA's 17 Priority Pollutants (see table

3.8), ozone depleting chemicals (ODCs), items

containing recycled content, Emergency Planning

and Community Right-to-Know Act chemicals,

municipal solid waste (MSW) and hazardous

waste;

• Measures progress toward objectives; and

• Identifies projects needed to achieve the pollution

prevention objectives and documents the programs

to accomplish those projects.

9.2.1. Pollution Prevention Management Plan Goals.

Goals for pollution prevention are established in the Air

Force Pollution Prevention Plan (7 January 1993). The

goal of reducing hazardous waste by 25% from a 1992

baseline by 1995 and 50% from the 1992 baseline by 1999

are directly applicable to hazardous waste generating

activities. Projects which demonstrate how an installation

will achieve these goals should be identified in the

installation's Pollution Prevention Management Plan.

9.2.2. The Pollution Prevention Management Plan should

also address affirmative procurement of environmentally

friendly products, energy conservation, and air and water

pollutant reduction. Many pollutant reduction methods

can be identified through opportunity assessments.

9.3. Waste Minimization Hierarchy. The Pollution

Prevention Act (PPA) of 1990, encourages waste

generators to adopt new principals guiding waste

management practices. There is a hierarchy of waste

minimization practices and management options to assist
AFPAM 32-7043 1 November 1995 93

in the reduction and elimination of hazardous material use

and waste generation. The hierarchy (see table 9.1)

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.

9.4. Team Approach. Program implementation requires

a team approach. All Air Force members have a role and

responsibility to enhance the environmental quality at

their installation. Worker training, awareness, and

compliance are integral to a successful program.

Pollution prevention will only succeed with a commitment

from all levels of personnel and a commitment from all

levels of management to support environmental awareness

and promote continuous improvement.

9.5. Benefits of Pollution Prevention. There are strong

incentives to reduce both the volume and toxicity of the

waste generated and hazardous materials used at

installations. An efficient, continuous Pollution

Prevention Program results in the following advantages:

9.5.1. Reduced overall waste treatment costs;

9.5.2. Reduced manpower and equipment requirements

for pollution control and treatment;

9.5.3. Reduced transportation and disposal costs for offsite disposal;

9.5.4. Decreased record-keeping requirements;

9.5.5. Reduced liability costs (reduce or eliminate fines

for non-compliance);

9.5.6. Reduced operating costs through more efficient use

of materials (decreased energy costs);

9.5.7. An improved image in the community;

9.5.8. Reduced operating costs through the use of more

efficient technologies; and

9.5.9. Reduced impact on public health and environment,

which can help foster good relationships with regulators.

9.6. Pollution Prevention Regulatory Requirements.

Several Federal regulations have begun to focus on source

reduction in lieu of end-of-the-pipe treatment, though the

primary focus of existing Federal laws is still on singlemedia compliance and clean-up. Some laws and

regulations contain waste minimization or source

reduction requirements.

9.6.1. Pollution Prevention Act (PPA). The PPA states

the national policy of the United States is that pollution

should be prevented or reduced at the source whenever

feasible; pollution that cannot be prevented should be

recycled in an environmentally safe manner, whenever

feasible; pollution that cannot be prevented or recycled

should be treated in an environmentally whenever

feasible; and disposal or other release into the

environment should be employed only as a last resort and

should be conducted in an environmentally safe manner.

The PPA requires source reduction and recycling data to

be provided by facilities on the annual toxic chemical

release form under section 313 of the Superfund

Amendments and Reauthorization Act of 1986 (SARA).

AFI 32-7080, Pollution Prevention Program, implements

the PPA.

9.6.2. RCRA. The RCRA biennial report must describe

efforts undertaken during the year to reduce the volume

and toxicity of waste generated, and changes in volume

and toxicity of waste achieved during the year in

comparison to previous years. Hazardous waste manifests

require certification that a program is in place to

minimize wastes. Recently, EPA has outlined the

requirements for ensuring that a waste minimization

program is in place in its Interim Final Guidance on the

Elements of a Waste Minimization Program. The

requirements outlined in this guidance are similar to those

outlined in the Air Force pollution prevention program.

9.6.3. Executive Order 12586. EO 12586, Federal

Compliance with Right-to-Know Laws and Pollution

Prevention Requirements, 3 August 1993, requires all

Federal Agencies to establish guidelines to comply with

the requirements of the Emergency Planning and

Community Right-to-Know Act, also known as SARA

Title III. Section 313 of SARA Title III requires the

reporting of toxic chemical emissions over the threshold

levels established. Federal facilities are required to

provide documentation of procedures for preventing the

releases of or for reusing these substances on the U.S.

EPA Form R, the Toxic Chemical Release Reporting

Form, for inclusion in the Toxic Release Inventory (TRI)

database.

9.6.4. Executive Order 12873. EO 12873, Federal

Acquisition, Recycling, and Waste Prevention, 20 October

1993, requires Federal agencies to incorporate waste

prevention (source reduction) and recycling in the

agency’s daily operations and work to increase and

expand markets for recovered materials through greater

Federal Government preference and demand for such

products. Agencies must establish policies to acquire and

use environmentally preferable products and services and

implement cost-effective procurement preference

programs favoring the purchase of these product and

services. Hazardous waste minimization is a key to

meeting EO 12873.

9.6.5. State Laws. A large number of states have

pollution prevention or waste minimization laws that may

also be applicable to an Air Force Installation's Pollution

Prevention Management Plan. Local environmental

authorities can provide additional insight regarding the

requirements posed by existing pollution prevention,

source reduction, and waste minimization laws.
94 AFPAM 32-7043 1 November 1995

9.7. Meeting Pollution Prevention Goals. There are

many ways to assist the Air Force in meeting its Pollution

Prevention goals. Each individual that handles or

generates hazardous wastes plays an important role in

implementing pollution prevention. One of the simplest,

most efficient ways of instituting pollution prevention is

through the implementation of best management

practices. Best management practices such as knowing

what wastes may be hazardous, keeping them segregated

from non-hazardous wastes, inventory management, and

disposing of wastes properly are the first steps toward

achieving waste reductions in your shop. Perhaps less

material is required than currently used, maybe some of

the wastes that are disposed of can be recycled, perhaps

less hazardous materials can be used in the processes

resulting in little or no hazardous waste generation.

Creativity and efficiency are integral to pollution

prevention. Many engineering options are also being

instituted such as bead blasting devices to strip paint off

of aircraft. This practice eliminates the need for the use of

hot and cold stripper, is less hazardous to the worker, and

generates significantly less waste than the previously used

process. Methods such as this can save the Air Force

money and prevent pollution.

9.8. Quarterly Summaries. The environmental

manager provides quarterly summaries of hazardous waste

generation data, prior year data, and year minimization

base year data to the installation Environmental

Protection Committee (EPC) for evaluating progress in

minimizing hazardous waste.

Table 9.1. Waste Minimization Management Options Hierarchy.

Method Example Activities Example Applications

Source Reduction

(Highest Priority)

This is Pollution Prevention.

Process Changes

Input Material Changes

Technology Changes

Improved Operating

Practices (usually the

quickest and most cost

effective)

Product Changes

Source Elimination

Inventory Control

Waste Segregation

Established Procedures and

Training

Improved Equipment

Substitution with Less Toxic

Material in Process

Modify Product to Avoid

Solvent Use

Modify Product to Extend

Coating Life

Recycling

This is Pollution Control. Reuse

Reclamation

Closed-Loop

Recycling/Reuse

Solvent Recycling (off-site)

Metal Recovery from a Spent

Plating Bath

Volatile Organic Compounds

(VOC) Recovery

Treatment

This is Pollution Control.

Stabilization

Encapsulation

Neutralization

Precipitation

Evaporation

Incineration

Scrubbing

Volume Reduction

Thermal Destruction of

Organic Solvent

Precipitation of Heavy Metal

from Spent Plating Bath

Disposal

This is Pollution Control.

Disposal at a Permitted

Facility

Land Disposal
AFPAM 32-7043 1 November 1995 95

____________________________________________________________________________________________________

Chapter 10

HAZARDOUS WASTE MANAGEMENT PLAN

10.1. Overview. A hazardous waste management plan is

an installation developed document which provides

specific guidance to installation personnel for hazardous

waste management and pollution prevention. All Air

Force installations must develop and implement a

comprehensive hazardous waste management plan. The

plan incorporates applicable current DoD, Air Force,

EPA, OSHA, DOT, State or host nation, and local

requirements regarding the management of hazardous

waste as they relate to environmental protection, worker

safety, and transportation during operations conducted at

the installation. If the Defense Reutilization and

Marketing Office is used as a disposal agent, the plan

must also incorporate the hazardous waste turn-in

requirements in DoD 4160.21-M, Defense Reutilization

and Marketing Manual with change 1. Attachment 2

contains a sample hazardous waste management plan.

10.2. Hazardous Waste Management Plan Elements.

The hazardous waste management plan must contain, as a

minimum, the following elements listed:

Hazardous Waste Management Plan Elements:

• Letter of Instruction

• Information and Emergency

Contacts.

• Introductory Materials

• Introduction.

• Responsibilities

• Organizational Chart.

• Location Maps

• Waste Inventory

• Waste Analysis Plan

• HW Management Procedures

• Reporting

• Training

• Contingency Plan

• Preparedness & Spill Prevention

• Pollution Prevention

10.2.1. Letter of Instruction. The plan should be

implemented with a facility-wide instruction signed by the

installation commander. This endorsement will mandate

compliance with the plan by all activities generating or

otherwise involved in the management of hazardous

waste.

10.2.2. Information and Emergency Contacts.

Although the plan is not intended to be a replacement for

the installation HAZMAT plan (see chapter 6), a current

list of information and emergency contacts should be

included as the first page of the plan. At a minimum, this

list should include telephone numbers and extensions for

the organizations listed in table 10.1.

Table 10.1. Information and Emergency Contacts.

On-Installation Contacts:

Fire Department

Emergency Medical Care

Command Post

Civil Engineer Service Call

Environmental Manager

 Bioenvironmental Engineering Services

Ground Safety Officer

Public Affairs Officer

Contracting Officer

Staff Judge Advocate

MAJCOM Contacts:

Command Post

Environmental Planning

EPA Regional Office (or equivalent host

nation environmental agency office)

National Response Center: 1-800-424-8802

Local Community Emergency

Response/Reporting Agency

State Emergency Response/Reporting Agency
96 AFPAM 32-7043 1 November 1995

10.2.3. Introductory Materials. The hazardous waste

management plan should include the following items

which will assist the user in finding and implementing

applicable portions of the plan.

10.2.3.1. Table of contents.

10.2.3.2. Record of Annual Review. The hazardous

waste management plan should be reviewed annually by

the installation environmental manager. As part of this

review, the following should be accomplished.

10.2.3.2.1. Each organization which uses hazardous

materials or generates hazardous waste should be

contacted to determine if there have been any changes in

the type or volume of wastes generated or hazardous

materials management procedures which have not yet

been documented in the plan.

10.2.3.2.2. Changes in DoD, Air Force, EPA, OSHA,

DOT, host nation, and state and local regulations and

policies should be reviewed and compared to the

hazardous waste management plan to identify plan

guidance and procedures which require modification.

10.2.3.2.3. The plan should be revised and coordinated

through applicable installation organizations.

10.2.3.2.4. The person that conducted the review should

add his or her name, date, and remarks to the record of

annual review. The HAZMAT Planing team should be

involved in the review process.

10.2.3.2.5. Copies of the hazardous waste management

plan revisions should be distributed to organizations to

which the original plan was distributed.

10.2.3.3. Record of Changes. If any changes in the

hazardous waste management plan are made, the change

number, name of person entering the changes, and the

date of the change should be added to the record of

changes.

10.2.3.4. Lists of Tables and Figures.

10.2.4. Introduction. This section should present the

goals of the installation's hazardous waste management

efforts. It may also include a brief overview of the scope

of Air Force, Federal, state, and installation requirements

and procedures for the management of hazardous waste.

10.2.5. Responsibilities. The duties and responsibilities

of all personnel and organizations involved with the

management of hazardous waste or who are otherwise

involved in the implementation of the hazardous waste

management plan should be summarized in this section.

This will outline the organization's and individual's

taskings and responsibilities and provide a basis for

determining performance. This section will describe

responsibilities for weighing their hazardous waste going

to disposal and identify DoD authorized representatives

that are responsible for verifying accuracy of weight

measurements. Installation responsibilities for ensuring

the hazardous waste management plan is updated as

necessary when changes have occurred in applicable

Federal, state, interstate, and local hazardous waste laws

should also be included.

10.2.6. Organizational Chart. A chart showing all of

the installation's units and tenants. This item is included

for the benefit of the regulators that will be reviewing the

plan.

10.2.7. Location Maps. The location map should show

the perimeter of the installation, main streets, and

buildings and the areas where hazardous waste is

generated, stored, and treated. Generating activity maps

should identify the location at each facility where

hazardous waste is accumulated, stored, and treated.

These maps should identify the type of operation (e.g.,

accumulation site, initial accumulation point, permitted

storage, etc.).

10.2.8. Waste Stream Inventory. This section contains

a description of the hazardous waste streams generated at

each Air Force installation. See paragraph 3.6 and table

3.5 for further information.

10.2.9. Waste Analysis Plan. Each installation which

generates hazardous waste is required to determine which

of the wastes they generate are classified as hazardous

waste in accordance with 40 CFR Part 261. Every Air

Force installation that generates hazardous waste will

have a waste analysis plan that is included in this section

of the hazardous waste management plan which shows

how this determination is made. See paragraph 3.4.1. for

further information.

10.2.10. Waste Management Procedures. This section

contains the proper procedures for waste characterization,

accumulation, labeling, marking, record keeping,

handling, transportation, treatment, storage, and disposal.

It provides generating activities with detailed procedures

for each operation involving hazardous waste

management in accordance with Air Force regulations

and policies as well as the regulations promulgated by the

EPA (40 CFR Parts 260 - 271), and state and local

agencies. This section is normally divided into four areas:

waste accumulation; waste turn-in; operation of permitted

facilities; and record keeping.

10.2.10.1. RCRA requires that hazardous waste

generators and TSDFs maintain specific records regarding

the results of each hazard determination, the quantity of

wastes generated, facility inspection, hazardous waste

manifests, land disposal notifications, and employee

training. Guidance for the development and maintenance

of these records is provided throughout the guide. This

section of the hazardous waste management plan should

identify organizations with specific record keeping

requirements, present record keeping forms, and

instructions for completion, disposition, and retention of

the records.

10.2.11. Reporting. RCRA requires hazardous waste

generators and permitted facilities to submit certain

reports regarding the types and quantity of wastes

generated, environmental releases, and manifest

irregularities. This section of the hazardous waste

management plan should identify organizations with
AFPAM 32-7043 1 November 1995 97

specific reporting requirements, present instructions for

submission of the reports, and the retention of the records

regarding reports submitted.

10.2.12. Training. This section should identify personnel

who must be trained, the scope of the required training,

training frequency, and include a plan for ensuring that

all applicable personnel successfully meet the training

requirements. Guidance for the development of an

installation training plan is presented in chapter 8 of this

pamphlet.

10.2.13. Contingency Plan. The location and availability

of the complete contingency plan should be referenced in

the hazardous waste management plan along with a

summary of the contingency plan. The summary should

identify the conditions under which the plan shall be

implemented, and should identify the organizations who

should be contacted in the event of a spill, fire, or

explosion involving hazardous waste.

10.2.14. Preparedness & Spill Prevention. Depending

on the type of wastes managed, certain emergency

response equipment must be available on site. The

hazardous waste management plan must include the

location and required inventory of the spill cleanup

equipment for each initial accumulation point,

accumulation site, TSDF, and all other locations where

spill cleanup equipment and supplies are stored. If it is

foreseeable that off-site organizations, such as the local

fire department, police department, hospital, spill

response team, etc., may be called upon to assist in

responding to an incident involving hazardous waste,

agreements with these organizations must be made which

document their ability to assist the installation. The

hazardous waste management plan should refer to these

agreements and copies should be placed in the HAZMAT

plan.

10.2.15. Pollution Prevention. Pollution prevention will

be an executive management strategy that may be attached

to the hazardous waste management plan or a stand-alone

plan that is referenced by the hazardous waste

management plan. See chapter 9 for further guidance.

JAMES E. McCARTHY, Maj General, USAF

The Civil Engineer
98 AFPAM 32-7043 Attachment 1 1 November 1995

GLOSSARY OF REFERENCES, ABBREVIATIONS, ACRONYMS, AND TERMS

References

Public Law 94-580, Resource Conservation and Recovery Act of 1976, 42 United States Code (U.S.C.), Sections 6901, et

 seq.

Public Law 96-510, Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42 U.S.C. Sections

 9602, et seq.

Public Law 102-386, Federal Facility Compliance Act of 1990, 42 U.S.C., Section 6961, et seq.

Public Law 99-499, The Emergency Planning and Community Right-to-Know Act of 1986, 42 U.S.C., Sections 11001, et

 seq.

Executive Order 12856, Federal Compliance with Right-to-Know Laws and Pollution Prevention Requirements, 3 August

 1993

Executive Order 12873, Federal Acquisition, Recycling, and Waste Prevention, 20 October 1993

Title 49, Code of Federal Regulations, Hazardous Materials Regulations, Parts 171-178

Title 40, Code of Federal Regulations, Hazardous Waste Regulations, Parts 260-268

Title 29, Code of Federal Regulations, Part 1910.120, Hazardous Waste Operations and Emergency Response

Title 29, Code of Federal Regulations, Part 1910.1200, Hazard Communication Standard

DoD 4160.21-M, Defense Reutilization and Marketing Manual with change 1, 30 April 1994

DoDD 5100.50, Protection and Enhancement of Environmental Quality with changes 1 and 2, 24 May 1973

DoDD 6050.8, Storage and Disposal of Non-DoD-Owned Hazardous or Toxic Materials on DoD Installations, 27 February

 1986

DoD 6055.9-STD, DoD Ammunition and Explosives Safety Standards, 30 October 1992

AFPD 32-70, Environmental Quality

AFI 32-4002, Hazardous Materials Emergency Planning and Response Compliance

AFI 32-7042, Solid and Hazardous Waste Compliance

AFI 32-7045, Environmental Compliance Assessment and Management Program

AFI 32-7001 Environmental Budgeting

AFI 32-7080, Pollution Prevention Program

AFI 48-119, Medical Service Environmental Quality Programs

DRMS-M 6050.1, Environmental Compliance for the DRMS Hazardous Property Program

AFMAN 64-108, Service Contracts

AFPAM 32-4013, Hazardous Materials Emergency Planning and Response Guide

AFOSH Standard 91-31, Protective Clothing and Other Equipment

AFOSH Standard 91-32, Emergency Shower and Eyewash Units

AFOSH Standard 91-43, Flammable & Combustible Liquids

AFOSH Standard 91-56, Fire Protection and Prevention

AFOSH Standard 91-68, Chemical Safety

AFOSH Standard 48-1, Respiratory Protection Program

AFOSH Standard 48-8, Controlling Exposures to Hazardous Materials

AFOSH Standard 48-21, Hazard Communication

AFOSHTD 161-21.1W and AFOSHTD 161-21.1G, DoD Federal Hazard Communication Training Program

DoT, Emergency Response Guidebook, Latest Edition (Sources: American Trucking Association, 1-800-ATA-LINE;

 Labelmaster, 1-800-621-5808; and J.J. Keller & Associates, 1-800-327-6868)

EPA, Test Methods for Evaluating Solid Waste, Volumes 1a through 1c and Volume 2, Field Manual, Physical/Chemical

 Methods, Third Edition EPA SW-846, Order Number: PB 88239223, Cost $154.00 (Source: National Technical

Information System, 5285 Port Royal Road, 703-487-4650)

EPA, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, Final Update #1, EPA SW-846, Order

Number: PB 94170313, Cost $112.00 (Source: National Technical Information System, 5285 Port Royal Road, 703-487-

 4650)

EPA, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, Proposed Update #2, EPA SW-846, Order

 Number: PB 94170321, Cost $126.00 (Source: National Technical Information System, 5285 Port Royal Road, 703-487-

 4650)

EPA, Guidance to Hazardous Waste Generators on the Elements of a Waste Minimization Program, Interim Final

 Guidance, Federal Register, Volume 58, No. 102, 28 May 1993 (Source: RCRA Hotline, 1-800-535-0202 or

 1-800-424-9346)
AFPAM 32-7043 Attachment 1 1 November 1995 99

FEMA/DoT/EPA, Handbook of Chemical Hazard Analysis Procedures (Source: RCRA/CERCLA/EPCRA Hotline,

 1-800-535-0202 or 1-800-424-9346)

National Fire Protection Association Standard 30, Flammable and Combustible Liquids Code (Source: National Fire

 Protection Association, 1 Batterymarch Park, P.O. Box 9101, Quincy, MA 02269-9904, 1-800-344-3555)

The Hazardous Waste Consultant, McCoy and Associates (Source: McCoy and Associates, 13701 West Jewell Avenue,

 Suite 252, Lakewood, Colorado 80228

Abbreviations and Acronyms

AFCESA Air Force Civil Engineer Support Agency

AFI Air Force Instruction

AFMC Air Force Materiel Command

AFO Accounting and Finance Office

AFOSH Air Force Occupational Safety and Health

AFPAM Air Force Pamphlet

AFRES Air Force Reserve

AS Accumulation Site

BDAT Best Demonstrated Achievable Technology

BEE Bioenvironmental Engineer

BES Bioenvironmental Services

BMP Best Management Practice

CAA Clean Air Act

CAAA Clean Air Act Amendments

CBT Computer Based Training

CCW Constituent Concentrations in Waste

CCWE Constituent Concentrations in Waste Extract

CE Civil Engineer

CEQ Conditionally Exempt Small Quantity Generator

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended.

CFR Code of Federal Regulations

CLIN Contract Line Item Number

CONUS Continental United .States

CWA Clean Water Act

DoD Department of Defense

DoDAAC DoD Activity Address Code

DoT Department of Transportation

DoE Department of Energy

DRMO Defense Reutilization and Marketing Office

DRMS Defense Reutilization and Marketing Service

DTID Disposal Turn-in Document

ECAMP Environmental Compliance Assessment Management Program

EOD Explosive Ordnance Disposal

EPA Environmental Protection Agency

EPC Environmental Protection Committee

EPCRA Emergency Planning and Community Right-To-Know Act of 1986

FFCA Federal Facility Compliance Act of 1992

FR Federal Register

FOA Field Operating Agency

GOCO Government Owned Contractor Operated

HAZMAT Hazardous Material

HMIS Hazardous Materials Information System

HMT Hazardous Materials Table (49 CFR § 172.101)

HMTA Hazardous Materials Transportation Act

HQ Headquarters

HSWA Hazardous and Solid Waste Act

HW Hazardous Waste
100 AFPAM 32-7043 Attachment 1 1 November 1995

HWAP HW Analysis Plan

HWMP HW Management Plan

HWPS HW Profile Sheet

IAP Initial Accumulation Point

IBS Interfund Billing System

IC Incident Commander

ICS Incident Command System

IM Inter-modal

IRP Installation Restoration Program

LDR Land Disposal Restriction

LEPC Local Emergency Planning Committee

LQ Large Quantity Generator

MAJCOM Major Command

MIPR Military Interdepartmental Purchase Request

MSDS Material safety data sheets

NA North American

NGB National Guard Bureau

NRC National Response Center

NSN National Stock Number

OEL Occupational Exposure Limit

OPA Oil Pollution Act of 1990

OPR Office of Primary Responsibility

OSC On-Scene Commander

OSHA Occupational Safety and Health Act

PCB Polychlorinated Biphenyl

PEL Permissible Exposure Limit

PSF Permitted Storage Facility

PG Packing Group

PPE Personal Protective Equipment

PPMP Pollution Prevention Management Plan

RCRA Resource Conservation and Recovery Act of 1976, as amended

RQ Reportable Quantity

SAF Secretary of the Air Force

SARA Superfund Amendments and Reauthorization Act of 1986

SERC State Emergency Response Commission

SPCC Spill Prevention, Control and Countermeasures

SQ Small Quantity Generator

SWDA Solid Waste Disposal Act

TC Toxicity Characteristics

TCLP Toxicity Characteristic Leaching Procedure

TPQ Threshold Planning Quantity

TSCA Toxic Substances Control Act

TSDF Treatment, Storage, and Disposal Facility

TSD Treatment, Storage, and Disposal

TLV Threshold Limit Value

TWA Time Weighted Average

UN United Nations

WIMS-ES Work Information Management System-Environmental Subsystem

Terms

Contingency Plan--A document setting out an organized, planned, or coordinated course of action to be followed in case of

fire, explosion, or release of hazardous waste or hazardous waste constituents which threaten human health or the

environment.
AFPAM 32-7043 Attachment 1 1 November 1995 101

Emergency Coordinator--Person responsible for handling hazardous waste releases and emergencies under the Resource

Conservation and Recovery Act.

Environment--Includes water, air, or land and the interrelationship which exists among and between water, air, and land

and all living things.

Environmentally Preferable--Products or services that have a lesser or reduced effect on human health and the

environment when compared with competing products or services that serve the same purpose. This comparison may

consider raw materials acquisition, production, manufacturing, packaging, distribution, reuse, operation, maintenance, or

disposal of the product or service.

Extremely Hazardous Substance--Any substance listed in appendix A or appendix B of 40 CFR 355. Appendix A is an

alphabetical listing of extremely hazardous substances. Appendix B lists extremely hazardous substances in order of each

substance's Chemical Abstracts Service registry number.

Facility--For emergency planning purposes, the term "facility" in 40 CFR 355, as it applies to the Air Force, is considered

equivalent to an "installation."

Hazardous Substance--Any substance listed in 40 CFR 302, table 302.4.

HAZMAT--All hazardous substances, petroleum, natural gas, synthetic gas, acutely toxic chemicals, and other toxic

chemicals including hazardous waste.

HAZMAT Response Team--Administrative term used to identify the total number of installation personnel assigned and

trained to the appropriate level. The purpose of this team is to respond to HAZMAT incidents to prevent or reduce human

injury or death, property damage, product loss and environmental damage.

HAZMAT Planning Team--Consists of representatives from disaster preparedness, fire protection, environmental

management, bioenvironmental engineering, security police, staff judge advocate, safety, and the HAZMAT response team.

Other representatives should augment this team, when appropriate. The HAZMAT planning team establishes and oversees

the installation HAZMAT program.

Immediately Dangerous to Life and Health (IDLH)--The maximum level to which a healthy worker can be exposed for

30 minutes and escape without suffering irreversible health effects or escape impairing symptoms. These are exposure

concentrations established by NIOSH/OSHA as a guideline for selecting respiratory protection. As a rule, IDLH

concentrations should be an indication that appropriate respiratory protection is essential.

Incident Commander (IC)--Normally the senior fire official on-scene responsible for all decisions relating to the

management of the immediate incident scene. The IC reports to the OSC.

Incident Command System (ICS)--Nationwide system used to manage emergency incidents. Further information on the

ICS can be found in National Fire Academy's The Incident Command System, (NFA-ICS-SM), The National Emergency

Training Center, 1989; and Emergency Management Institute's Overview of the Incident Command System, (SM305.7),

The National Emergency Training Center, 1992.

Lethal Dose (LD)--The single dose of a substance that in laboratory tests is expected to kill a certain amount or percentage

of the test animals. It is based on ingestion (oral), absorption (skin) or injection. It can be expressed as milligrams of

material per kilogram of animal weight (mg/kg), or grams of material per kilogram of animal weight (g/kg). Two values

are normally seen: median lethal dose 50 (LD50); and lethal dose low (LDLo).

Lethal Concentrations (LC)--The concentration of a material in air that on the basis of laboratory tests is expected to kill a

certain amount or percentage of the test animals in a given period of time. It is based on inhalation, with the period of

exposure time from one to four hours. It can be expressed as parts of materials per million parts of air, by volume (ppm),

milligrams of material per cubic meter of air (mg/m3), or micrograms (one millionth of a gram) of material per liter of air

(ug/L). Two values are normally seen: median lethal concentration 50 (LC50); and lethal concentration low (LCLo).
102 AFPAM 32-7043 Attachment 1 1 November 1995

Local Emergency Planning Committee--A committee established by the state commission for each emergency planning

district to plan and coordinate local emergency response actions.

Occupational Exposure Limit (OEL)--The limit for the airborne concentration of a specified substance for a specified

time. Refer to AFOSH Standard 161-8, Controlling Exposures to Hazardous Materials, for further information.

Oil--Oil of any kind or in any form, including, but not limited to, petroleum, fuel oil, sludge, oil refuse, and oil mixed with

wastes other than dredged spoil.

On-Scene Commander--The person designated to coordinate the rescue efforts at the rescue site (JCS Publication 1-02).

The senior member, normally the installation or combat support group commander, of the disaster control group. All

disaster response force members at an accident scene are under the command and control of the on-scene commander.

During a HAZMAT incident response where the Disaster Control Group is activated, all disaster response force members

are under the command and control of the OSC. The senior fire official will serve as the OSC until a designated OSC

arrives and is briefed on the situation. Under 40 CFR 300, the National Contingency Plan, the term OSC designates a

federal on-scene coordinator. Because DOD provides their own coordinator, the on-scene commander fills this role.

Parts Per Million (ppm)--Parts of contaminants per million parts of air or liquid by volume.

Parts Per Billion (ppb)--Parts of contaminants per billion parts of air or liquid by volume.

Permissible Exposure Limit (PEL)--An exposure limit established by OSHA and have the force of law. PELs can be

found in 29 CFR 1910.1000, Subpart Z, General Industry Standards for Toxic and Hazardous Substances. They are

expressed as either 8-hour time weighted averages (TWA), ceiling limits (TLV-C), or short term exposure limits (STEL).

Release--Any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching,

dumping, or disposing into the environment (including the abandonment or discarding of barrels, containers, and other

closed receptacles) of any hazardous chemical, extremely hazardous substance, or toxic chemical.

Reportable Quantity--For any CERCLA [The Comprehensive Environmental Response, Compensation, and Liability Act

of 1980, as amended] hazardous substance, the reportable quantity is that listed in the "Final RQ" column of table 302.4 in

40 CFR 302. For an EPCRA [Emergency Planning and Community Right-To-Know Act] extremely hazardous substance,

the reported quantity is that listed in the "Reportable Quantity" column of appendix A or appendix B in 40 CFR 355.

Threshold Limit Value (TLV)--A TLV is a recommended guideline for good practice published by the American

Conference of Governmental Hygienists (ACGIH). TLVs refer to airborne concentrations of substances and represent

conditions under which it is believed that nearly all workers may be repeatedly exposed without adverse health effects.

TLVs are intended for use by individuals trained in the practice of industrial hygiene; therefore, individuals should seek

further information from their installation bioenvironmental engineering services. TLVs are expressed as 8-hour TWAs,

ceiling values, or short term exposure limits.

Threshold Limit Value Time Weighted Average (TLV-TWA)--The time weighted average concentration for a normal 8-

hour workday and a 40-hour workweek, to which all workers may be repeatedly exposed, day after day, without adverse

effect.

Threshold Limit Value Short Term Exposure Limit (TLV-STEL)--A 15 minute TWA exposure which should not be

exceeded at any time during the workday. Exposures above the TLV-TWA should not be longer than 15 minutes nor occur

more than four times per day, with at least 60 minutes between occurrences. It supplements the TLV-TWA where there are

recognized acute effects from a substance whose toxic effects are primarily of a chronic nature.

Threshold Limit Value Ceiling (TLV-C)--Concentration in air that should not be exceeded during any part of a working

exposure. Ceiling limits may supplement other units or stand alone.
AFPAM 32-7043 Attachment 2 1 November 1995 103

SAMPLE HAZARDOUS WASTE MANAGEMENT PLAN

(This is a sample only. This plan does not reflect actual conditions or

requirements at Andrews Air Force Base.)
104 AFPAM 32-7043 Attachment 2 1 November 1995

ANDREWS AIR FORCE BASE LETTER OF DISTRIBUTION

MEMORANDUM FOR INSTALLATION PERSONNEL

From: Installation Commander

Subject: Andrews AFB Hazardous Waste Management Plan (HWMP)

Enclosure: Hazardous Waste Management Plan, January, 1994

1. A comprehensive and mandatory hazardous waste management plan for Andrews Air Force Base and its tenants is

enclosed.

2. The enclosed plan has been prepared in accordance with DoD, Air Force, EPA, OSHA, DoT, and state environmental,

worker safety, and transportation requirements. The plan assigns responsibility and provides instruction for appropriate

waste handling and management to ensure conformance with the policies established by the agencies listed above.

3. This plan is applicable to all installation activities, tenant organizations, and contractors which generate, treat, store, or

respond to releases involving hazardous waste within the confines of Andrews AFB.

4. Implement and comply with the provisions of the hazardous waste management plan at all times.

JOHN J. DOE, Brigadier General, USAF

Wing Commander

Attachment:

Hazardous Waste Management Plan
AFPAM 32-7043 Attachment 2 1 November 1995 105

Andrews Air Force Base

Emergency Reporting and Information Numbers

REPORT ON-BASE EMERGENCIES TO

(fires, explosions, releases, or spills)

Base Fire Department 911

REPORT OFF-BASE EMERGENCIES INVOLVING AIR FORCE ASSETS TO

(fires, explosions, releases, or spills of hazardous waste off-base)

# 1. Local Emergency Reporting Number 911

# 2. Base Consolidated Command Post 555-3121

FOR CHEMICAL EMERGENCY INFORMATION AND ASSISTANCE

CHEMTREC 800-424-9300

FOR FEDERAL, STATE, AND LOCAL RELEASE NOTIFICATION/REPORTING

National Response Center 800-424-8802

State Emergency Response Commission 555-733-3867

State Release Reporting Number 800-555-7956

Local Emergency Response Commission 555-1172

FOR AIR FORCE RELEASE REPORTING TO MAJCOM

Command Post Autovon 555-2224

Environmental Staff Office Autovon 555-1234

FOR ON-BASE ASSISTANCE AND INFORMATION

Environmental Manager 3007 Bioenvironmental Engineer 3229

Civil Engineer Service Call 3009 Emergency Medical Services 3231

Ground Safety 3789 Security Police 3911

Public Affairs 3204 Contracting Officer 3798

Staff Judge Advocate 3445

FOR OFF-BASE ASSISTANCE AND INFORMATION

EPA RCRA/Superfund Hotline 800-424-9346

EPA Hazardous Waste Ombudsman Program 800-262-7937

EPA Emergency Planning & Community

 Right-to-Know Information Hotline 800-677-9424

EPA Region 4 404-347-3016

State Hazardous Waste Regulatory Authority 555-555-4321
106 AFPAM 32-7043 Attachment 2 1 November 1995

RECORD OF CHANGES

CHANGE NUMBER DATE ENTERED POSTED BY

C-1 06 Jul 94 TSgt T. Jeffers

RECORD OF ANNUAL REVIEW

REVIEWED BY DATE REVIEWED REMARKS

Mr. J. Madson 03 Jan 95 No changes required
AFPAM 32-7043 Attachment 2 1 November 1995 107

TABLE OF CONTENTS

Paragraph Page

Chapter 1 - Introduction

Section A--Background

Objective.......................................................................................................................... 1.1 000

Effective Dates................................................................................................................. 1.2 000

Implementation................................................................................................................ 1.3 000

Section B--Scope of the Hazardous Waste Management Program

Applicability to AAFB..................................................................................................... 1.4 000

Applicability of State Requirements................................................................................. 1.5 000

Chapter 2 − Responsibilities

Section A--Tasked Organizations

Overview........................................................................................................................... 2.1 000

Section B--Specific Responsibilities

Wing Commander (EPC Chairperson)............................................................................. 2.2 000

Civil Engineer ................................................................................................................. 2.3 000

Environmental Manager .................................................................................................. 2.4 000

Transportation Squadron Commander ............................................................................. 2.5 000

Bioenvironmental Engineer ............................................................................................. 2.6 000

Public Affairs Officer....................................................................................................... 2.7 000

Commanders of Generating Activities.............................................................................. 2.8 000

Hazardous Waste Accumulation Site Managers................................................................ 2.9 000

DRMO............................................................................................................................2.10 000

Explosive Ordnance Disposal..........................................................................................2.11 000

Ground Safety Officer.....................................................................................................2.12 000

Section C--Organization Chart

Chapter 3 - AAFB Hazardous Waste Stream Inventory and Locations

Section A--Hazardous Waste Locations

Hazardous Waste Accumulation Map............................................................................... 3.1 000

Hazardous Waste Accumulation Areas............................................................................. 3.2 000

Section B--Hazardous Waste Stream Inventory

Responsibilities................................................................................................................ 3.3 000

AAFB Hazardous Waste Stream Inventory....................................................................... 3.4 000

Chapter 4 - Andrews Air Force Base Waste Analysis Plan

Background Information.................................................................................................. 4.1 000

Hazardous Waste Characterization Process...................................................................... 4.2 000

Test Methods Used........................................................................................................... 4.3 000

Analytical Methods.......................................................................................................... 4.4 000

Hazardous Waste Sampling Methods............................................................................... 4.5 000

Sampling Analysis Location and Frequency..................................................................... 4.6 000

Sample Documentation.................................................................................................... 4.7 000

Sample Request Procedures.............................................................................................. 4.8 000

Hazardous Waste Profile Sheet......................................................................................... 4.9 000

Waste Analysis Plan Revision.........................................................................................4.10 000

Chapter 5 - Andrews Air Force Base Hazardous Waste Management Procedures

Specific Waste Management Procedures .......................................................................... 5.1 000

Permitted Hazardous Waste Storage Facility .................................................................... 5.2 000

Accumulation Site Management........................................................................................5.3 000
108 AFPAM 32-7043 Attachment 2 1 November 1995

Paragraph Page

Initial Accumulation Points............................................................................................. 5.4 000

Hazardous Waste Turn-in to DRMO ................................................................................ 5.5 000

On-Installation Transportation......................................................................................... 5.6 000

Record Keeping ............................................................................................................... 5.7 000

Reporting......................................................................................................................... 5.8 000

Chapter 6 − Training

Section A--Hazardous Waste Training Requirements

Personnel for Which Training is Mandatory .................................................................... 6.1 000

Training Frequency.......................................................................................................... 6.2 000

Section B--Training Scope

Training Components...................................................................................................... 6.3 000

Air Force Hazardous Waste Management Training Program............................................ 6.4 000

Required Records............................................................................................................. 6.5 000

Chapter 7 − Response to Emergencies

Emergency Response Procedures and Contingency Plan Requirements ............................ 7.1 000

Implementation................................................................................................................ 7.2 000

Chapter 8-Pollution Prevention

Pollution Prevention Program Plan .................................................................................. 8.1 000

Scope of the P3P .............................................................................................................. 8.2 000

Tables

3.1. AAFB Hazardous Wastes Accumulated at Initial Accumulation Points......................................... 000

3.2. AAFB Hazardous Wastes Accumulated at Accumulation Sites...................................................... 000

4.1. Waste Analysis Parameters for AAFB Hazardous Waste Streams.................................................. 000

4.2. Maximum Concentration of Contaminants for the Toxicity Characteristic .................................... 000

4.3. Table of Analytical Methods and SW-846 Numbers...................................................................... 000

4.4. Representative Sampling Method Protocols................................................................................... 000

5.1. Common Federal Stock Classes .................................................................................................... 000

5.2. RCRA Records and Corresponding Minimum Retention Periods .................................................. 000

Figures

2.1. AAFB Hazardous Waste Management Information Flow.............................................................. 000

3.1. Base Map Showing Hazardous Waste Accumulation and Storage Areas........................................ 000

3.2. AAFB Hazardous Waste Stream Inventory.................................................................................... 000

4.1. Hazardous Waste Profile Sheet for AAFB Waste Stream AB-001.................................................. 000

5.1. EPA Hazardous Waste Mark......................................................................................................... 000

5.2. Accumulation Site Container Log ................................................................................................. 000

5.3. Sample AF Form 2005, Issue/Turn-In Request.............................................................................. 000

5.4. Sample DD Form 1348-1 Disposal Turn-in Document.................................................................. 000
AFPAM 32-7043 Attachment 2 1 November 1995 109

Chapter 1

INTRODUCTION

Section A--Background

1.1. Objective. The United States Air Force is committed to proper management of the hazardous wastes that are

generated on its installations. The primary objective of this document is to provide a management plan that gives personnel

involved with hazardous waste the essential tools for effective management.

1.2. Effective Dates. On May 19, 1980, the U.S. Environmental Protection Agency (EPA) published the hazardous waste

management system rules. Subtitle C of the Solid Waste Disposal Act, as amended by the Resource Conservation and

Recovery Act of 1976 (RCRA), as amended, directed the EPA to promulgate these rules and regulations to protect human

health and the environment from the improper management of hazardous waste. The effective date of these far-reaching

regulations was November 19, 1980. RCRA was again amended in 1984. The amendments require increased management

of hazardous waste by all organizations on Andrews Air Force Base (AAFB). Because the State has developed a program to

implement the RCRA requirements, the EPA has delegated RCRA implementation to the State. The Federal Facility

Compliance Act (FFCA) of 1992 requires all DoD facilities to comply with all applicable Federal, state, interstate, and local

environmental regulations in the same manner as private facilities. The FFCA allows Federal and state agencies to assess

fines against DoD facilities with RCRA violations. The procedures of this plan will be used to comply with Federal and

state legislation and regulations. Plan revisions shall reflect changes in either level of hazardous waste management laws

and regulations. Each revision to this plan will become effective immediately upon distribution unless otherwise noted

herein.

1.3. Implementation. Implementation of the comprehensive hazardous waste management program mandated by RCRA

requires maximum cooperation of all activities on AAFB. It is the responsibility of the installation commander to ensure

compliance with all RCRA requirements for AAFB and to notify, apply for permits, and report to EPA or the State, as

required, for all installation activities, including tenant activities. The individual base operational units (generating

activities) are accountable for conducting their activities in accordance with this plan. Those base units, including

supporting Defense Reutilization and Marketing Service activities and tenant activities, will provide necessary

documentation to the installation commander through the Environmental Protection Committee for permit application,

provide the reports required by EPA or the State, and ensure compliance with RCRA regulations and permit requirements at

the facility.

Section B--Scope of the Hazardous Waste Management Program

1.4. Applicability to AAFB. This plan deals with key points in implementing the complex area of hazardous waste

management required by RCRA as enforced by the EPA at Federal facilities such as AAFB. Federal facilities are not

exempt from most of the requirements of this law. The plan covers the control and management of hazardous wastes at the

point where they are generated from hazardous materials to the point of ultimate disposal. This plan implements the EPA’s

philosophy of “cradle-to-grave” management and control of hazardous waste.

1.5. Applicability of State Requirements. This plan also addresses mandatory requirements of the state of State

Hazardous Waste Management regulations. AAFB is not exempt from state regulations which have been authorized by

EPA to implement RCRA requirements in this state.
110 AFPAM 32-7043 Attachment 2 1 November 1995

Chapter 2

RESPONSIBILITIES

Section A--Tasked Organizations.

2.1. Overview. Responsibilities for implementing this plan are distributed throughout base organizations that generate,

accumulate, store, transport, turn-in, monitor, treat, dispose of, or respond to incidents involving hazardous waste.

Compliance with Federal, State, and local hazardous waste laws and regulations is the responsibility of the installation

commander through the Environmental Protection Committee (EPC). The development, maintenance, and implementation

of this plan is the result of Andrews AFB Environmental Protection Committee action. The following organizations are

tasked under this plan: Tactical Training Wing (EPC Chairperson); Civil Engineer Squadron; Supply Squadron;

Transportation Squadron; Training Group; Medical Group; Aircraft Generation Squadron; Component Repair Squadron;

Equipment Maintenance Squadron; Tactical Air Control Wing; Tactical Air Support Squadron; Defense Reutilization and

Marketing Office (DRMO); Det. 1, Fighter Interceptor Group; Aerospace Maintenance and Regeneration Center; Electronic

Combat Squadron; Bulk Fuel Company; Engineering Support Branch, USMCR; and Contracting.

Section B-Specific Responsibilities

2.2. Tactical Training Wing (EPC Chairperson).

2.2.1. Ensures that management of hazardous waste on AAFB complies with applicable portions of 40 CFR Parts 260-271

and State Hazardous Waste Management Regulations

2.2.2. Ensures the hazardous waste management plan is updated at least annually.

2.2.3. Signs installation hazardous waste permit applications.

2.2.4. Ensures all hazardous waste manifests are signed.

2.2.5. Ensures all personnel involved with hazardous waste have the required training and receive refresher training.

2.2.6. Ensures all enforcement actions are resolved quickly.

2.3. CES/CE.

2.3.1. In conjunction with DRMO, operates and maintains the hazardous waste storage facility.

2.3.2. Provides emergency notification through the emergency reporting number maintained by the Fire Protection Flight.

2.3.3. Reviews and signs the hazardous waste management plan record of annual review.

2.3.4. Ensures the hazardous waste management training is provided annually.

2.3.5. Equips the installation hazardous materials (HAZMAT) response team.

2.4. CSG/CEV (Environmental Manager).

2.4.1. Manages the base hazardous waste program.

2.4.2. Updates the hazardous waste management plan.

2.4.3. Conducts or coordinates hazardous waste management training for all base personnel who handle or who may be

otherwise involved in the management of hazardous waste. Maintains training documentation for a minimum of 3 years.

2.4.4. Signs hazardous waste manifests and prepare hazardous waste reports and compliance documentation as required by

EPA, state regulatory agency, and Air Force instructions.

2.4.5. Performs hazardous waste management compliance surveys of AAFB.

2.4.6. Maintains records of hazardous waste management surveys of AAFB.

2.4.7. Prepares and submits annual reports to the EPA and State Hazardous Waste Enforcement Authority.

2.4.8. Coordinates with Federal, State, county, and city authorities on hazardous waste management procedures.

2.4.9. Develops and coordinates compliance with a Closure/Post-Closure Plan for the hazardous waste storage facility.

2.4.10. Develops a AAFB Closure/Post-Closure Plan that addresses each hazardous waste accumulation site.

2.4.11. Prepares permit applications as required. Coordinates permit applications with TTW/CC.

2.4.12. Provides Public Affairs Office with a fact sheet on the base hazardous waste management program. The fact sheet

will contain an overview of RCRA and State requirements, the number and location of permitted storage and treatment

facilities and accumulation sites, inventory of hazardous waste, key base hazardous waste management plan organizations,

and an explanation of the waste disposal and recycling process. The fact sheet will be updated as required.

2.4.13. Maintains a written operating record. The following information will be recorded as it becomes available and will

be perpetually maintained until the event of base or facility closure:
AFPAM 32-7043 Attachment 2 1 November 1995 111

• Facility layout plan.

• Location of each hazardous waste initial accumulation point (IAP) within each generating activity's facility and the

quantity at each IAP.

• Records and results of waste analysis and trial tests.

• Summary reports and details of all incidents that require implementing the hazardous waste contingency portion of

the installation's HAZMAT plan.

• Records and results of inspections.

2.4.14. Provides all applicable records to authorized representatives of the EPA or State regulatory agency.

2.4.15. Maintains routine liaison with HQ MAJCOM, EPA, and State regulatory agency in regard to hazardous waste

inspections, rule interpretation, and problem resolution.

2.4.16. Assists waste generating activities in hazardous waste characterization (identification, description, and

quantification), accumulation, storage, marking and labeling, waste minimization, waste recycling, waste turn-in, and

disposal.

2.4.17. Ensures all hazardous waste is accurately weighed for disposal actions.

2.4.18. Acts as alternate emergency coordinator.

2.4.19. Ensures funding requirements are identified and allocates funds based upon regulatory requirements.

2.5. Transportation Squadron.

2.5.1. Provides safe transportation of hazardous waste from hazardous waste accumulation sites to the on-base permitted

hazardous waste storage facility as a service to base hazardous waste generating activities which do not have adequate

equipment to safely transport waste on-base on their own.

2.5.2. Only transports hazardous waste on-base if it is in approved containers deemed to be in good condition.

2.5.3. Provides guidance to base organizations on approved containers for accumulating and shipping hazardous waste.

2.5.4. Provides transportation of hazardous wastes generated during emergency contingency conditions.

2.5.5. Ensures that hazardous waste cargo is adequately secured and safe for transport before moving.

2.6. Medical Group/SGPB (Bioenvironmental Engineering Services).

2.6.1. Collects (or assist in collection of) samples for hazardous waste determination and forwards to USAF Armstrong

Laboratory or a local contract laboratory for analysis in accordance with the sampling and analytical requirements specified

in EPA Publication SW-846 and the AAFB Waste Analysis Plan.

2.6.2. Forwards analytical results to appropriate generating activity and Environmental Manager.

2.6.3. Interprets analytical results and assists base generating activities and the environmental management function in

preparing DRMS Form 1930, Hazardous Waste Profile Sheet.

2.6.4. Monitors ground water and surface water outfalls for contamination.

2.6.5. Receives and reviews Materials Safety Data Sheets (MSDSs) or DoD Hazardous Materials Information System

(HMIS) for all current and new hazardous materials sheets on the installation.

2.6.6. Informs LGS of any special actions or assignment of Issue Exception Codes (IEX) based on the review of MSDSs or

HMIS.

2.6.7. Specifies personal protective equipment to be worn by personnel occupationally exposed to or who may otherwise

manage hazardous waste.

2.6.8. Participates in hazardous waste training programs and exercises.

2.6.9. Coordinates with accumulation site managers, Environmental Manager, Fire Protection Flight, and Ground Safety

on location of hazardous waste initial accumulation points and accumulation sites.

2.6.10. Develops and updates the installation's Waste Steam Inventory and Waste Analysis Plan.

2.7. Public Affairs Office (PAO).

2.7.1. Acts as the focal point for inquiries from the news media and concerned citizens regarding hazardous waste and in

the event of a hazardous waste incident or accident.

2.7.2. Assists the On-Scene Commander during situations involving hazardous waste incidents by keeping interested news

media and the public aware of events and curtailing rumors through the dissemination of coordinated, accurate information.

Responds to the accident/incident site, to the Command Post, and to the Public Affairs duty section where an information

center may be established.

2.7.2.1. The presence of hazardous waste in a contained area will probably not constitute reasonable cause to forcibly deny

access to the area by accredited news media representatives. Applicable security and safety provisions will apply, however.
112 AFPAM 32-7043 Attachment 2 1 November 1995

Under no circumstances will Public Affairs Office personnel escort news media representatives into a hazardous or

potentially dangerous area without permission from the On-Scene Commander.

2.8. Commanders of Generating Activities.

2.8.1. Submits requests to CSG/CEV and Medical Group/SGPB, in turn, to ensure that all wastes are evaluated and that

hazardous wastes are properly classified.

2.8.2. Provides safe equipment and locations for initial accumulation points and accumulation sites. Coordinate each

location with Environmental Manager, Ground Safety, Fire Protection Flight, and Bioenvironmental Engineering Services.

2.8.3. Ensures that the management of hazardous waste initial accumulation points and accumulation sites complies with

Federal and State hazardous waste management regulations.

2.8.4. Appoints the shop supervisor of shops that generate hazardous waste as the hazardous waste accumulation site

manager. The accumulation site manager retains overall responsibility for the management of the accumulation site. For

military supervisors, management duties may be delegated by the shop supervisor, but to no lower than an E-5 (Staff

Sergeant). Waivers to this requirement may be submitted to CEV if hazardous waste generating shops cannot comply

because of personnel and/or rank limitations.

2.8.5. Allows appropriate facilities, shops, and equipment to be inspected for hazardous waste management regulatory

compliance by installation fire, safety and health personnel, CEV personnel, ECAMP team members, and authorized State

or Federal inspectors.

2.8.6. Ensures all personnel that handle hazardous waste or who are otherwise involved in hazardous waste management

receive annual and refresher training.

2.8.7. Ensures each generating activity properly completes all required documentation (hazardous waste profile sheet, AF

Form 2005, DD Form 1348-1, and hazardous waste manifest for transport along public highways).

2.8.8. Maintains a hazardous waste file for each hazardous waste stream within the generating activity (hazardous waste

profile sheets, AF Form 2005s, DD Form 1348-1s, waste analysis results, and hazardous waste manifests).

2.9. Hazardous Waste Accumulation Site Managers.

2.9.1. Assumes overall responsibility for management of the hazardous waste accumulation site and initial accumulation

points serviced by the site.

2.9.2. Coordinates with Environmental Manager, Fire Protection Flight, Bioenvironmental Engineering Services, and

Ground Safety on relocation of initial accumulation points and accumulation sites.

2.9.3. Ensures initial accumulation points and accumulation site has appropriate warning signs.

2.9.4. Ensures that the accumulation site has an release response kit.

2.9.5. Ensures that an approved fire extinguisher is readily available if flammable hazardous waste is handled at an initial

accumulation points or stored in the accumulation site.

2.9.6. Performs and documents inspections of the accumulation site. Inspections must be performed weekly for containers

and daily for tanks.

2.9.7. Ensures that hazardous wastes are collected and stored in approved containers. Coordinate with CEV and

Transportation Officer regarding container selection.

2.9.8. Ensures that hazardous wastes are in appropriate (authorized) containers capable of being loaded and transported. A

representative of the generating activity must accompany the vehicle operator to DRMO.

2.9.9. Maintains hazardous waste containers in proper condition, e.g., no pitting, no sharp edge creases or dents, no

material defects, no bulging heads.

2.9.10. Ensures that containers are kept closed except when they are being filled.

2.9.11. Ensure that all hazardous waste is placed in an approved accumulation site.

2.9.12. Ensures that hazardous waste is not placed in a container that is not properly marked. There must never be a doubt

about the contents of a container holding hazardous waste.

2.9.13. Ensures that hazardous waste containers are properly painted/marked before they receive any hazardous waste.

2.9.13.1. Marks the following information on the hazardous waste label or container:

• the words "HAZARDOUS WASTE";

• proper shipping name (and technical name);

• national stock number;

• contaminants and estimated percentages of each;

• accumulation start date (the date that the first amount of hazardous waste was placed into the container at

accumulation sites; or when the volume limit was met at initial accumulation points); and

• the AAFB assigned container number.
AFPAM 32-7043 Attachment 2 1 November 1995 113

2.9.14. Ensures that the placement of a new hazardous waste container in its accumulation site is accompanied by a

simultaneous entry of the placement in the inspection log. Continue updating the log entry for all containers until they are

turned into DRMO. Under no circumstances shall a hazardous waste container be placed in any accumulation site without

there being a proper entry in the weekly inspection log.

2.9.15. Ensures that the storage of hazardous waste in the accumulation site does not exceed 90 days.

2.9.16. Provides initial hazardous waste management training to personnel who handle hazardous waste. Coordinates

training with CEV.

2.9.17. Documents the training and submits a copy of the documentation to CEV. The documentation must include the

following:

• job title for each position relating to hazardous waste and name of employee filling each job;

• a written description for each position (must include the required skill, education, or other qualifications and duties

of personnel assigned to each position);

• a written description of type and amount of introductory and continuing training; and

• documentation that hazardous waste management training has been given to and completed by appropriate

personnel.

2.9.18. Provides annual hazardous waste management refresher training to all personnel who handle hazardous waste.

Documents the training and submits a copy of the documentation to CEV.

2.9.19. Properly annotates the AF Form 2005 and DD Form 1348 prior to processing the hazardous waste through Base

Supply, CEV and DRMO. Completes and updates the DRMS Form 1930, Hazardous Waste Profile Sheet prior to waste

turn-in.

2.9.20. Implements emergency response. When a hazardous waste spill is detected, stop all other actions and contain spill

to best of ability based on unit capability, resources, and the procedures described in the HAZMAT Plan. Activate the

installation's response process by calling the installation's emergency reporting number.

2.9.21. Maintains all hazardous waste documentation and correspondence for a minimum of 5 years.

2.10. DRMO.

2.10.1. Receives from generating activities hazardous property and waste except explosive ordnance.

2.10.2. Disposes of hazardous property by reutilization, resale or service contract.

2.10.3. Provides guidance on turn-in procedures to base personnel.

2.10.4. Maintains all hazardous waste documentation and correspondence for a minimum of 5 years.

2.10.5. Conducts and documents hazardous waste management training for all DRMO personnel.

2.10.6. Forwards a copy of the hazardous waste management training records to CSG/CEV.

2.10.7. Develops and follows a written schedule for inspecting the permitted storage facility.

2.10.8. Conducts and documents weekly inspections (daily if loading or unloading hazardous waste) at the permitted

storage facility. Takes remedial action as required.

2.10.9. Submits required copies of hazardous waste manifests to applicable agencies as required.

2.10.10. Takes precautions to prevent accidental ignition or reaction of ignitable or reactive waste.

2.10.11. Maintains required aisle space.

2.10.12. Keeps an operating record of the facility as required by 40 CFR § 264.73 and § 264.74.

2.10.13. Ensures that containers holding ignitable or reactive waste are located at least 50 feet inside the facility property

line.

2.10.14. Inspects and, if necessary, has Environmental Manager analyze each hazardous waste before accepting it for

storage.

2.10.15. Verifies accuracy of hazardous waste weight measurements prior to waste acceptance.

2.11. EMS/EOD:

2.11.1. Develops and follows a written inspection schedule.

2.11.2. Inspects the EOD range before and after each EOD operation in accordance with the inspection schedule.

2.11.3. Conducts and documents hazardous waste management training for all EOD personnel. Provides copies of training

documentation to CEV.

2.11.4. Ensures that all munitions items that are classified as hazardous waste received from off-base are accompanied by

the required hazardous waste manifest.

• Signs and dates each copy of the manifest.

• Notes all discrepancies in the manifest.

• Immediately gives one copy of the manifest to the transporter.

• Immediately sends one copy of the manifest to the generating activity.
114 AFPAM 32-7043 Attachment 2 1 November 1995

• Send two copies of the manifest to CEV within 30 days.

2.11.5. Maintains a written operating record as required by 40 CFR § 264.73 and § 264.74.

2.11.6. Maintains a log of explosives that are destroyed by explosive class, net explosive weight, and origin. Forwards a

copy to CEV annually by 1 Feb.

2.11.7. Ensures that all munitions items are accountable from receipt to destruction.

2.11.8. Maintains all hazardous waste documentation for a minimum period of five years because all hazardous waste is

now covered by the land disposal restrictions.

2.12. TTW/SEG. Inspect hazardous waste accumulation sites during the regular annual ground safety inspection. All

safety items will be inspected and made part of the formal inspection report.

Section C--Organization Chart.

Figure 2.1 graphically describes the correct direction that information regarding hazardous waste management should flow.

Figure 2.1. AAFB Hazardous Waste Management Information Flow.

INSTALLATION

COMMANDER

PUBLIC

AFFAIRS

CIVIL ENGINEER

BASE GROUND ENVIRONMENTAL BIOENVIRONMENTAL

SUPPLY SAFETY MANAGER ENGINEER

ACCUMULATION

SITE MANAGER

ACCUMULATION

SITE MANAGER

TRANSPORTATION

PERSONNEL

DRMO

IAP SHOP

PERSONNEL

IAP SHOP

PERSONNEL
AFPAM 32-7043 Attachment 2 1 November 1995 115

Chapter 3

ANDREWS AIR FORCE BASE HAZARDOUS WASTE STREAM INVENTORY AND LOCATIONS

Section A--Hazardous Waste Locations

3.1. Hazardous Waste Accumulation Map. The map on page 117 shows areas and buildings at AAFB where hazardous

wastes are initially accumulated (initial accumulation points), accumulated by the generating activities for up to 90 days

from the time the first volume of hazardous waste is placed in a container or moved into the areas by the generating

activities (accumulation sites), and the building where hazardous waste may be stored for longer periods of time prior to

disposal (permitted storage).

3.2. Hazardous Waste Accumulation Areas.

3.2.1. An initial accumulation point is an area where waste is initially accumulated under control of the shop supervisor of

the process generating the waste. The maximum volume of hazardous waste permitted at each initial accumulation point is

55 gallons or one quart of acute hazardous waste on the P-list. Once one of these limits is exceeded, the waste must be

moved to its designated waste accumulation site. Their are four initial accumulation points for hazardous waste at Andrews

Air Force Base. The areas designated as initial accumulation points are identified below in Table 3.1. If an additional

initial accumulation point is needed, a location near the area where the waste is generated will be selected by the area

accumulation site manager who will notify the Environmental Manager.

Table 3.1. AAFB Hazardous Waste Initial Accumulation Points.

Building Organization Waste Stream # Manager Phone Number

207 AMARC Paint Shop PO-001 Mr. Smith 3521

207 AMARC Paint Shop PO-002 Mr. Jones 3529

213 ECS-AGE AC-001 TSgt. Blue 3988

213 ECS-AGE FC-001 TSgt. Ross 3968

3.2.2. A hazardous waste accumulation site is an area near the waste generating activity where hazardous waste is

accumulated in containers or tanks for a period of up to 90 days. AAFB only accumulates hazardous waste in containers.

There are three accumulation sites for hazardous waste at AAFB. The areas designated for the accumulation of hazardous

waste are identified below in Table 3.2. If an additional accumulation site is needed, a location near the area where the

waste is generated will be selected by the area accumulation site manager in coordination with the Environmental Manager

who will ensure that the area selected and the design of the accumulation site minimizes the threat of the waste to human

health or the environment.

Table 3.2. AAFB Hazardous Wastes Accumulation Sites.

Building Organization Waste Stream # Manager Phone Number

207 AMARC Paint Shop PO-001

PO-002

Mr. Adams 3523

213 ECS-AGE AC-001

FC-001

TSgt. Alcot 3973

214 CES Protect Coat Shop AB-001 Mr. Andrews 3620

3.2.3. A permitted storage facility is an area in which a facility has been granted a permit to store hazardous waste in

accordance with permit STATED1234567890. DRMO operates the hazardous waste storage facility in Building 198. The

permit should be referred to for specific operating procedures and restrictions. Wastes restricted from land disposal may be

stored at this facility for up to one year. It is the policy of AAFB to ship hazardous waste off-site as expeditiously as

possible.
116 AFPAM 32-7043 Attachment 2 1 November 1995

Section B--Hazardous Waste Steam Inventory

3.3. Responsibilities.

3.3.1. Andrews Air Force Base maintains a hazardous waste stream inventory for every hazardous waste stream generated

on base. Bioenvironmental Engineering Services (BES) is the office of primary responsibility for the AAFB hazardous

waste stream inventory. AAFB will not handle, store, transport, dispose of or inventory non-DOD owned hazardous wastes

or materials except as authorized.

3.3.2. AAFB will ensure that all wastes are properly characterized and classified as either hazardous or non-hazardous

wastes in accordance with the AAFB Waste Analysis Plan (See Chapter 4). Hazardous wastes will be characterized on the

DRMS Form 1930, Hazardous Waste Profile Sheet. Information from the hazardous waste profile sheet will be used by

Bioenvironmental Engineering Services to maintain and update the hazardous waste stream inventory. The accumulation

site manager is responsible for quantifying all hazardous waste streams for the hazardous waste stream inventory.

3.3.3. Hazardous waste generating activities will identify and separately document wastes which are classified as nonhazardous due to the following:

• subject to solid or hazardous waste exclusions (40 CFR § 261.4);

• recycled, not subject to the generator waste determination requirements of 40 CFR § 262.11 (e.g., lead acid batteries

that are being reclaimed, used oil that is burned for energy recovery, and scrap metal which is recycled) (40 CFR §

261.6);

• land disposal restricted waste that is excluded from the definition of hazardous or solid waste or exempt from Subtitle

C regulations under 40 CFR 261.2-261.6 subsequent to the point of generation, to document the waste, its exclusion

or exemption, and the disposition of the waste.

3.3.4. The hazardous waste generating activity of an area generating an excluded, exempt, or recycled waste will place a

one-time notice stating such generation, the subsequent exclusion from the definition of solid or hazardous waste or

exemption from Subtitle C regulation, and the disposition of the waste in the generating activity's waste management file.

A copy of the document will be forwarded to the Environmental Manager and maintained on-site for at least five years from

the date the waste was last sent to on-site or off-site treatment, storage, or disposal.

3.4. Andrews Air Force Base Hazardous Waste Stream Inventory. Figure 3.2 shows the hazardous waste stream

inventory for the five hazardous waste streams generated by AAFB.
AFPAM 32-7043 Attachment 2 1 November 1995 117

Baker Road

Barrett Ave

New Street

Berry Street

Murray Lane

Coho Lane

North Gate 

South Gate 

Figure 3.1. Base Map Showing Hazardous Waste Accumulation and Storage Areas.

0 1 2 3 4 5 6 7

A

B

C

D

E

F

G

198

219

303

Hospital

301 302

401

402

2

3

0

4

4

0

3

4

0

4

5

0

6

5

0

5

5

0

2

5

0

3

5

0

1

504

204

206

205

211

203

202

H-1

H-2

Aircraft

Parking

Apron

36

01

A

n

d

r

e

w

s

D

r

i

v

e

H

a

z

a

r

d

D

r

i

v

e

 Fire Dept.

DRMO

Initial Accumulation Point (IAP) Accumulation Site (AS) Permitted Facility

North

 1200 ft 
118 AFPAM 32-7043 Attachment 2 1 November 1995

Figure 3.2 Hazardous Waste Stream Inventory.

HAZARDOUS WASTE STREAM INVENTORY

Date: 6 Jun 94 Contact Name/Preparer: Andrews Telephone Number: 3620

Installation: Andrews Air Force Base Organization Code: CES

Waste

Stream

Location

(Shop/Bldg)

Waste

Stream

Number

Estimated

Quantity

Disposed

Hazardous

Waste

Criteria

Exhibited &

Concentration

Limits

EPA/State

Hazardous

Waste ID

Number

EPA

Priority

Pollutant

Number

Disposal

Container

Disposal

Method

Protective

Coating Shop

Grid: D-6

Bldg: 207

AB-001

Waste

Abrasive

Blasting

Media with

Paint Chips

20,000 lb/yr T-Chromium

(125 mg/l)

(SW-6010)

T-Lead

(360 mg/l)

(SW-6010)

D007, D008 5, 8 Drum DRMO

Date: 6 Jun 94 Contact Name/Preparer: : Adams/Smith Telephone Number: 3525

Installation: Andrews Air Force Base Organization Code: EMS

Waste

Stream

Location

(Shop/Bldg)

Waste

Stream

Number

Estimated

Quantity

Disposed

Hazardous

Waste

Criteria

Exhibited &

Concentration

Limits

EPA/State

Hazardous

Waste ID

Number

EPA

Priority

Pollutant

Number

Disposal

Container

Disposal

Method

AMARC

Grid: B-5

Bldg: 207

PO-001

Waste Paints

& Thinners

4,800 lb/yr I-Flashpoint

120°F

(SW-1010)

F-Xylene

(1-11%)

D001, F003 17 Drum DRMO

AMARC

Grid: B-5

Bldg: 207

PO-002

Spent PD 680

Type I Still

Bottom

7,000 lb/yr I-Flashpoint

95°

F

(SW-1010)

T-Chromium

(150 mg/l)

(SW-6010)

D001, D007 5 Drum REC

DRMO

(100 lbs

still

bottoms per

month

disposed

via DRMO)
AFPAM 32-7043 Attachment 2 1 November 1995 119

Figure 3.2 Continued.

HAZARDOUS WASTE STREAM INVENTORY

Date: 6 Jun 94 Contact Name/Preparer: TSgt Alcot Telephone Number: 3973

Installation: Andrews Air Force Base Organization Code: ECS

Waste

Stream

Location

(Shop/Bldg)

Waste

Stream

Number

Estimated

Quantity

Disposed

Hazardous

Waste

Criteria

Exhibited &

Concentration

Limits

EPA/State

Hazardous

Waste ID

Number

EPA

Priority

Pollutant

Number

Disposal

Container

Disposal

Method

AGE

Grid: E-5

Bldg: 213

AC-001

Solvent

Contaminated

Rags

1,000 lb/yr

F-Cotton Rags

(80-90%)

F-1,1,1-

Trichloroethane

(5-10%)

T-Benzene

(5860 mg/l)

(SW-8240)

F001, D018 1, 15 Drum DRMO

AGE

Grid: E-5

Bldg: 213

FC-001

Contaminated

Aircraft Fuel

20,000 lb/yr I-Flashpoint

12°

F

(SW-1010)

T-Benzene

(5860 mg/l)

(SW-8240)

D001, D018 1 Drum DRMO
120 AFPAM 32-7043 Attachment 2 1 November 1995

Chapter 4

ANDREWS AIR FORCE BASE WASTE ANALYSIS PLAN

4.1. Background Information.

4.1.1. Federal and State Requirements. This is the waste analysis plan for Andrews Air Force Base as required by 40

CFR § 264.13(a), (b), and (c), 40 CFR § 268.7, 40 CFR § 270.14(b)(5), State Regulations, and Air Force Policy. The waste

analysis plan applies to all AAFB hazardous waste streams that are transferred to the DRMO-operated permitted storage

area (building 198).

4.1.2. Andrews Air Force Base Plan Contents. To comply with Federal and State RCRA requirements, this plan

contains base procedures for identifying and evaluating hazardous waste streams in order to complete a hazardous waste

profile sheet on each hazardous waste stream. The waste analysis plan describes detailed procedures for obtaining physical

and chemical analyses from all associated waste generating activities at AAFB including procedures for selecting waste

parameters for analysis, selecting waste sampling methods, documenting samples, identifying analytical methods, selecting

facilities for analyzing samples, and reevaluating hazardous waste streams.

4.1.3. Waste Steam Inventory. The AAFB hazardous waste stream inventory lists all hazardous waste streams transferred

to Building 198 and other hazardous waste streams where storage in excess of 90 days is not permitted. The hazardous

waste process codes used in the hazardous waste stream inventory can be cross-referenced to the waste analysis plan

procedures to identify the sampling and analytical procedures which apply to specific hazardous waste streams generated at

AAFB.

4.2. Hazardous Waste Characterization Process.

4.2.1. Hazardous waste characterization will involve three sequential steps: 1) waste identification, 2) waste description, 3)

waste quantification.

4.2.1.1. Waste Identification.

4.2.1.1.1. Waste identification is a process in which all newly generated wastes at AAFB are evaluated to determine

whether the waste is hazardous or non-hazardous. Waste identification also involves classifying hazardous wastes. This

process can be conducted either by using the waste generator’s knowledge of the waste or by analytical testing. In either

case, all evaluations must be based on the EPA solid waste and hazardous waste definitions. Analytical testing is required

at Andrews Air Force Base for all waste streams which are chemical mixtures. Testing is not normally required for waste,

unused, commercial chemical products or laboratory chemicals in their original, marked containers.

4.2.1.1.2. Bioenvironmental Engineering Services will determine if the generator’s knowledge of the waste is sufficient to

characterize the waste. The generating activity should request a hazardous waste determination through the Environmental

Manager to Bioenvironmental Engineering Services. If testing is needed, Bioenvironmental Engineering Services will

arrange for sample and analysis. Sampling and analysis must be conducted in accordance with the requirements specified

in EPA publication SW-864 and this waste analysis plan. All sampling and analysis costs will be funded from the

installation operations and maintenance funds.

4.2.1.1.3. The waste generating activity should ask the following questions to determine if they have a hazardous waste

stream which requires further evaluation:

4.2.1.1.3.1. Is it a waste? If the answer to any of the following four questions is yes, the material is a waste.

• Is the material no longer useful for its intended purpose because it is dirty, out of specification, or a spill residue?

• Is it an unintended or unusable byproduct?

• Does the base intend to discard the material for eventual treatment, storage, recycling, or disposal?

• Is it produced by cleanup at a previously uncontrolled waste site?

4.2.1.1.3.2. Is it a solid waste? A solid waste is generally defined as any discarded material (including solids, liquids, and

containerized gases) which is abandoned, recycled, or considered inherently waste-like.

4.2.1.1.3.3. Is it a hazardous waste? If the material is a solid waste, the solid waste must be evaluated to determine if it is

a hazardous waste. A material is a hazardous waste if it has not been excluded from regulation and is a characteristic

hazardous waste (e.g., ignitable, corrosive, reactive, or toxic), a listed hazardous waste, or a mixture of a listed hazardous

waste and solid waste. This evaluation can be conducted by either using the waste generator's knowledge of the hazardous

characteristics of the waste in light of the materials or processes used, or by analytical testing as described 40 CFR 261 and

this waste analysis plan.

4.2.1.2. Waste Description. The analytical results must be interpreted to determine if tested waste streams are hazardous

according to 40 CFR Part 261 or State definitions. Bioenvironmental Engineering Services is responsible for interpreting

the analytical test results for the Environmental Manager. Bioenvironmental Engineering Services should mark the test

results as "HAZARDOUS WASTE" or "NOT HAZARDOUS WASTE" after making a determination. The analytical
AFPAM 32-7043 Attachment 2 1 November 1995 121

results as well as the generating activities waste process knowledge will be used to complete the hazardous waste profile

sheet. The generating activity will obtain assistance in completing the hazardous waste profile sheet from the

Environmental Manager, Bioenvironmental Engineering Services, and the Base Transportation Officer.

4.2.1.3. Waste Quantification. The final step is determining the amount of hazardous waste generated each year, which is

documented in the hazardous waste inventory (see Chapter 3).

4.3. Test Methods Used.

4.3.1. Waste Stream Screening. Three industrial work centers at AAFB generate wastes; all waste is transferred to

Building 198. All new waste streams must be evaluated by the generating activity as soon as they are generated and prior to

leaving the waste generating area.

Table 4.1. Waste Analysis Parameters for AAFB Hazardous Waste Streams.

Waste Stream Number Waste Description Parameters

PO-001 Waste paints and thinners Flash point, TCLP (metals), BTU

value, and ash content

PO-002 Still bottoms from PD-680 recycling Flash point, TCLP (metals), and ash

content

AC-001 Rags containing oil,1,1,1-trichloroethane TCLP (metal, volatiles, semi-volatiles)

and 1,1,1-Trichloroethane

FC-001 Fuel contaminated with water, oil Flash point, BTU value, and ash

content

AB-001 Waste abrasive blasting media with paint TCLP (metals)

4.3.2. Waste Parameter Selection.

4.3.2.1. Table 4.1 lists all of the existing wastes streams at AAFB by waste stream number and identifies the specific

parameters that are analyzed for each waste stream. Analytical testing for the specified parameters must be repeated

annually unless the waste generating process or the materials comprising the wastes change. If the waste generating

process or waste characteristics change, the waste must be retested prior to disposal. The parameters selected for new waste

streams will be based on the waste characterization information required in the waste disposal contract for the waste. As a

minimum, new waste streams will be evaluated using the Toxicity Characteristic Leaching Procedure (TCLP) to determine

toxicity characteristics unless the generator's knowledge of the waste is sufficient to rule out the presence of any of the

toxicity characteristic contaminants.

4.3.2.2. The waste parameters selected above are based on the suspected hazardous waste characteristics of the waste.

• Flash Point. Flash point is determined through a test procedure which identifies whether a waste is ignitable

(D001). Ignitable hazardous wastes have flash points less than 140°F. Hazardous waste streams PO-001, PO-002,

and FC-001 contain varying concentrations of ignitable solvents which have the potential to lower the waste's flash

point to less than 140°F. Because process knowledge is not adequate to accurately predict flash point, these waste

must be retested each year by December 1 to determine flash point.

• BTU Value and Ash Content. The disposal contract through the DRMO for hazardous waste streams PO-001,

PO-002, and FC-001 specifies that BTU value and ash content will be analyzed each year by December 1 to

determine if these hazardous waste streams are suitable for fuel blending and use in an energy recovery program. To

be accepted, these wastes must have a minimum heating value of 5000 BTU/lb and an ash content no higher than 5

percent.

• TCLP Metals. If an extract from a representative sample of waste, which when tested in accordance with the

Toxicity Characteristic Leaching Procedure, contains any of the contaminants listed in Table 4.2 at a concentration

equal to or greater than the regulatory level listed in the table, the waste is a hazardous waste. Toxicity characteristic

constituents which are metals of concern include arsenic, barium, cadmium, chromium, lead, mercury, selenium, and

silver. Hazardous waste streams PO-001, PO-002, and AB-001 have the potential to contain lead and

chromium-based paint pigments and must be analyzed for the TCLP metals each year by December 1.
122 AFPAM 32-7043 Attachment 2 1 November 1995

• TCLP Metals, Volatiles and Semi-Volatiles. Rags from aircraft cleaning operations have the potential to absorb

toxicity characteristic contaminants such as lead and benzene. A TCLP analysis for all contaminants listed in Table

4.2 except pesticides will be completed on hazardous waste stream AC-001 each year by December 1.

• 1,1,1-Trichloroethane Concentration. Spent 1,1,1-trichloroethane used for cleaning and degreasing is a listed

hazardous waste (F001). If waste rags contain any detectable concentration of spent 1,1,1-trichloroethane, they also

must be classified as an F001 waste. Waste rags soaked with this solvent will be analyzed annually to determine

their 1,1,1-trichloroethane concentration and hazardous waste code(s).

4.3.2.3. All new and non-recurring hazardous waste streams, except for laboratory chemicals and unused commercial

chemical products, must be tested in accordance with the TCLP to determine if they exhibit the toxicity characteristic,

except when process knowledge is sufficient to certify that none of the TCLP contaminants could be present. In addition,

the major components of each hazardous waste stream must be defined on the hazardous waste profile sheet. If process

knowledge is insufficient, these wastes will be tested to determine their major components. A major component includes any

hazardous constituent listed in Appendix VIII of 40 CFR Part 261 present over 10,000 ppm (1%). If process knowledge is

insufficient to identify major components, then testing for those components in accordance with the procedures outlined in

EPA's Publication SW-846 will be necessary. Additional testing (e.g., flash point, BTU value, ash content, pH, etc.) will be

based on the testing requirements specified in the disposal contract for the waste.

4.3.2.4. AAFB waste oil and oil filters, which are recycled off-site by being burned for energy recovery, are not regulated as

a hazardous waste if they contain less than 1000 ppm of total halogens. Each batch of waste oil and filters will be screened

for total halogens (TOX) by submitting a representative sample of the waste oil to Bioenvironmental Engineering Services

four weeks prior to pickup by the waste oil hauler. All waste oil is assumed to be off-specification used oil fuel at AAFB in

accordance with EPA regulations in 40 CFR 266.40.

4.4. Analytical Methods.

4.4.1. Several of the parameters specified above will be analyzed using the test methods from EPA’s “Test Methods for

Evaluating Solid Waste, Physical/Chemical Methods" (EPA Publication SW-846). The SW-846 method numbers are

specified in Table 4.3.

4.4.2. The hazardous waste analysis for all of the above waste streams will be conducted at the Armstrong Laboratory (AL

The AL is accredited by the American Association of Laboratory Accreditation and is approved by the Texas Water

Commission for the analysis of wastewater, hazardous waste, Superfund site, underground injection, and underground

storage tank program samples.
AFPAM 32-7043 Attachment 2 1 November 1995 123

Table 4.2. Maximum Concentrations of Contaminants for the Toxicity Characteristic.

 EPA Hazardous Waste Number Contaminant Regulatory Level (mg/l)

D004 ...................................................................Arsenic ..............................................................................5.0

D005 ...................................................................Barium...........................................................................100.0

D018 ...................................................................Benzene .............................................................................0.5

D006 ...................................................................Cadmium...........................................................................1.0

D019 ...................................................................Carbon Tetrachloride .........................................................0.5

D020 ...................................................................Chlordane ........................................................................0.03

D021 ...................................................................Chlorobenzene ...............................................................100.0

D022 ...................................................................Chloroform........................................................................6.0

D007 ...................................................................Chromium .........................................................................5.0

D023 ................................................................... o-Cresol ........................................................................200.02

D024 ...................................................................m-Cresol.......................................................................200.02

D025 ...................................................................p-Cresol........................................................................200.02

D026 ...................................................................Cresol ............................................................................200.0

D016 ...................................................................2,4-D ...............................................................................10.0

D027 ...................................................................1,4-Dichlorobenzene ..........................................................7.5

D028 ...................................................................1,2-Dichloroethane ............................................................0.5

D029 ...................................................................1,1-Dichloroethylene..........................................................0.7

D030 ...................................................................2,4-Dinitrotoluene.......................................................... 0.131

D012 ...................................................................Endrin .............................................................................0.02

D031 ...................................................................Heptachlor (and its hydroxide).......................................0.008

D032 ...................................................................Hexachlorobenzene ........................................................ 0.131

D033 ...................................................................Hexachlorobutadiene..........................................................0.5

D034 ...................................................................Hexachloroethane ..............................................................3.0

D008 ...................................................................Lead...................................................................................5.0

D013 ...................................................................Lindane .............................................................................0.4

D009 ...................................................................Mercury .............................................................................0.2

D014 ...................................................................Methoxychlor...................................................................10.0

D035 ...................................................................Methyl Ethyl Ketone ......................................................200.0

D036 ...................................................................Nitrobenzene......................................................................2.0

D037 ...................................................................Pentachlorophenol .........................................................100.0

D038 ...................................................................Pyridine ........................................................................... 5.01

D010 ...................................................................Selenium............................................................................1.0

D011 ...................................................................Silver.................................................................................5.0

D039 ...................................................................Tetrachloroethylene ...........................................................0.7

D015 ...................................................................Toxaphene .........................................................................0.5

D040 ...................................................................Trichloroethylene...............................................................0.5

D041 ...................................................................2,4,5-Trichlorophenol ....................................................400.0

D042 ...................................................................2,4,6-Trichlorophenol ........................................................2.0

D017 ...................................................................2,4,5-TP (Silvex) ...............................................................1.0

D043 ...................................................................Vinyl Chloride ...................................................................0.2

1 Quantitation limit is greater than the regulatory level. The quantitation limit therefore becomes the regulatory

level.

2

If the o-, m-, and p-Cresol concentrations cannot be differentiated, the total cresol (D026) concentration is used.

The regulatory level of total cresol is 200 mg/l.
124 AFPAM 32-7043 Attachment 2 1 November 1995

Table 4.3. Table of Analytical Methods and SW-846 Numbers.

 Key Methods SW-846 Method Numbers

TCLP Metals SW-6010, 7470 (Hg)

TCLP Volatiles SW-8240

TCLP Semi-volatiles SW-8270

Ignitability SW-1010

Extraction SW-1311

Extraction Preparation for Flame/ICP SW-3010

Extraction Preparation for Furnace SW-3020

Extraction Preparation for Oils/Grease SW-3040

Extraction Preparation for Sludge SW-3050

Total Organic Halides SW-9020

Trichloroethane SW-8010, 8240

4.5. Hazardous Waste Sampling Methods.

4.5.1. All waste samples will be collected in accordance with procedures specified in this waste analysis plan and the

EPA-specified procedures identified in Table 4.4 to ensure that they are representative of the waste stream.

4.5.2. Both sampling equipment and sample bottles must be clean in order to prevent contamination of the sample. Sample

bottles used for holding samples which will be analyzed for metallics should be cleaned with detergent, rinsed with tap

water, rinsed with 1:1 nitric acid, rinsed with tap water, rinsed with 1:1 hydrochloric acid, rinsed with tap water, and finally

rinsed with Type II deionized water. Sample bottles used for holding samples which will be analyzed for organic

compounds should be washed with detergent, rinsed with tap water, rinsed with distilled, deionized water, and dried at 105°

C for approximately one hour.

Table 4.4. Representative Sampling Method Protocols.

 Sample Type Sampling Method

Extremely viscous liquids ASTM Standard D140-70

Crushed or powdered material ASTM Standard D346-75

Soil or rock-like material ASTM Standard D420-69

Soil-like material ASTM D1452-65

Fly ash-like material ASTM Standard D2234-76

Containerized Liquid Wastes US EPA SW-846 COLIWASA Procedure

Liquid wastes in pits, ponds, US EPA SW-846 Pond Sampler

 lagoons and similar reservoirs

4.5.3. Samples which are to be analyzed for volatiles must be placed in a cooler for storage and shipping to ensure that they

are cooled down to 4°C.

4.5.4. Sampling equipment (e.g., the COLIWASA) must be decontaminated before being reused by washing in a detergent

solution and rinsing. Alternatively, disposable COLIWASAs will be used and disposed of after each sample is collected.

4.5.5. Personnel collecting hazardous waste samples must wear personal protective equipment including impervious gloves,

chemical safety goggles, coveralls, and suitable boots when sampling hazardous waste. Bioenvironmental Engineering

Services should be contacted to determine the proper equipment to be worn when sampling specific waste streams. A

minimum of Level B protection (e.g., chemical splash suit, impervious gloves, impervious outer boots, and a positive

pressure self-contained breathing apparatus) must be worn when sampling unknown wastes streams.

4.6. Sample Analysis Location and Frequency.

4.6.1. Obtaining Samples of Liquid and Semisolid Wastes from Containers (Waste Streams PO-001, PO-002,

FC-001, and waste oil).

4.6.1.1. Each waste stream must be sampled. If the waste stream is contained in several containers, a homogeneous sample

should betaken. If there are a large number of containers, a subset of containers to be sampled will be chosen randomly by
AFPAM 32-7043 Attachment 2 1 November 1995 125

using a random number table. Any waste stream container which does not have a valid container log or was not secured to

prevent unauthorized waste from being placed into the container will require separate sampling.

4.6.1.2. Samples will be taken by inserting a COLIWASA through the bung on each drum, allowing the COLIWASA to fill

with the waste, inserting the plug into the end of the COLIWASA, and draining the contents of the COLIWASA into the

precleaned glass sample bottle.

4.6.1.3. It is important to keep air out of samples which will be analyzed for both TCLP and non-TCLP volatile organic

components. A minimum two 100 milliliter samples should be collected in a Teflon-lined, septum-capped vials and stored

and shipped at 4°C prior to analysis. When collecting samples of volatile organics, introduce the materials to the sample

vial gently to reduce agitation which might drive off volatile compounds. Liquid samples should be poured into the sample

vial without introducing any air bubbles within the bottle as it is being filled. Should bubbling occur as a result of violent

pouring, the sample must be poured out and the vial refilled. Each vial should be filled until there is a meniscus over the lip

of the vial. The screw top lid with the septum should then be tightened onto the vial. After tightening the lid, the vial

should be inverted and tapped to check for air bubbles. If there are any air bubbles present, the sample must be retaken.

4.6.2. Obtaining Samples of Free-Flowing Powders from Containers (Waste Stream AB-001).

4.6.2.1. Each waste stream must be sampled. If the waste stream is contained in several containers, a homogeneous sample

should betaken. If there are a large number of containers, a subset of containers to be sampled will be chosen randomly by

using a random number table. Any waste stream container which does not have a valid container log or was not secured to

prevent unauthorized waste from being placed into the container will require separate sampling.

4.6.2.2. A thief sampler will be used to obtain the sample. The sampler will be inserted into the top of the 55-gallon 17H

drum, pushed to the bottom of the drum, rotated several times to allow the sand media and paint chips to flow into the

chamber, removed from the drum, and emptied into the precleaned glass sample bottle.

4.6.2.3. Sampling equipment, (e.g., the thief sampler) must be decontaminated by washing in a detergent solution and

rinsing before being reused.

4.6.3. Obtaining Samples of Rags from Containers (Waste Stream AC-001).

4.6.3.1. Ideally several samples should be taken from locations dispersed both horizontally and vertically through the open

top 55-gallon drums (17H).

4.6.3.2. Sample bottles used for holding samples which will be analyzed for organic compounds should be washed with

detergent, rinsed with tap water, rinsed with distilled, deionized water, and dried at 105° C for approximately one hour.

4.6.3.3. The container to be sampled is divided by using an imaginary three-dimensional grid. Each section and level is

assigned a number and specific sampling locations are selected by using a random number table. A minimum of four rags

should be removed from the randomly selected locations and placed in a precleaned, glass sample bottle with a

septum-capped lid.

4.6.4. Each of the high volume waste streams identified in Table 4.1 will be sampled and the samples analyzed each year

by December 1 in order to update the hazardous waste profile sheet and to ensure that the initial hazardous waste

determinations are accurate and up-to-date. High volume waste streams are defined as those that generate four or more

55-gallon drums of waste per year. All AAFB waste streams are currently classified as high volume.

4.6.4.1. The accumulation site managers will request additional analyses from Bioenvironmental Engineering Services in

accordance with this plan whenever the process or operation generating the hazardous waste stream has changed. Prior to

turning in a waste to DRMO for disposal, the accumulation site manager must review the current hazardous waste profile

sheet to ensure that it still accurately reflects the characteristics, composition, and regulatory classification of the waste. If

there has been a change in the waste stream, additional analyses and an updated hazardous waste profile sheet may be

required.

4.6.4.2. If new waste streams are generated, the accumulation site manager will contact Bioenvironmental Engineering

Services for a determination of the sampling parameters and required analysis. This analysis and a hazardous waste profile

sheet will be completed by the accumulation site manager prior to waste turn-in to the DRMO or any other non-DRMO

disposal agent. The accumulation site manager must also make arrangements through the Environmental Manager for

weighing the waste prior to turn-in.

4.6.4.3. If any newly generated waste is estimated to generate 3 55-gallon drums or less per year, it is considered a low

volume waste stream. It will be sampled and analyzed once every three years after the initial analysis and characterization

unless there is a process change that would dictate a more frequent analysis. An updated hazardous waste profile sheet

must be submitted to the DRMO by December 1 of each year for low volume waste streams, but the reevaluation may be

based on process knowledge after the initial analytical characterization.

4.7. Sample Documentation.

4.7.1. Andrews Air Force Bases uses sample labels, analysis request forms, and chain-of-custody forms for all waste sample

shipments to ensure the integrity of samples from collection to data reporting. The possession and handling of samples
126 AFPAM 32-7043 Attachment 2 1 November 1995

must be traceable from collection through analysis and final disposition. The documentation of the sample history is called

chain-of-custody.

4.7.1.1. The parts of the chain-of-custody process include the use of sample labels which are placed on containers prior to

sampling and filled out by Bioenvironmental Engineering Services or accumulation site manager at sample collection.

Necessary information on the sample label includes the sample number, name of collector, date and time of collection, and

place of collection.

4.7.1.2. A chain-of-custody record should also be filled out and accompany every sample. This record should contain the

sample number, signature of collector, date and time of collection, place and address of collection, waste type, signature of

persons involved in the chain of custody, and inclusive dates of possession. Bioenvironmental Engineering Services will

provide the Chain-of-Custody form.

4.8. Sample Request Procedures. A sample analysis request form should accompany the sample to the laboratory. The

field portion of the form is completed by the person collecting the sample and should include pertinent information such as

the sample number, the requested analysis, and the name and phone number of the person collecting the sample. The

sample analysis request form will typically be provided by the laboratory conducting the analysis. The laboratory portion of

the form is then completed by laboratory personnel and includes the name of the person receiving the sample, laboratory

sample number, date and time of sample receipt, sample allocation, and analysis to be performed.

4.9. Hazardous Waste Profile Sheet.

4.9.1. After analytical results have been received from the laboratory, the data must be evaluated to determine if the

material is a hazardous waste and to ensure compliance with the AAFB waste analysis plan. Bioenvironmental

Engineering Services should interpret the results for the waste generator, provide a copy of the results to the waste generator

and the Environmental Manager, and keep a copy on file. The file copy should be maintained for at least five years from

the date that the waste was last shipped off-installation, because all waste is land disposal restricted waste.

4.9.1.1. The analytical results are used by the accumulation site manager to complete a comprehensive waste stream

description which is recorded on the hazardous waste profile sheet. All analytical results from waste evaluation activities

should be attached to the hazardous waste profile sheet.

4.9.1.2. A sample hazardous waste profile sheet for waste stream AB-001 is presented in Figure 4.1.

4.9.2. The hazardous waste profile sheet is the standard form which must be used for characterizing hazardous waste for all

disposal actions, regardless of whether or not the DRMO in Building 198 is the disposal agent. The hazardous waste profile

sheet is available from the local DRMO. If the local DRMO is not the disposal agent, the hazardous waste profile sheet can

be obtained from the base Environmental Manager.

4.9.2.1. The DRMO uses the information that is contained on the hazardous waste profile sheet to alert disposal contractors

of possible disposal restrictions. The DRMO representative assigns an initial reference number to each hazardous waste

profile sheet. Subsequent turn-ins of the same waste do not require that the hazardous waste profile sheet accompany the

waste. Instead, the generating activity simply places the reference number in the “Remarks” section (block AA) of the

Disposal Turn-In Document (DTID).

4.9.2.2. The accumulation site managers can obtain base support for completing the profile sheet as follows:

• The Environmental Manager (CEV) will advise on completion of Part I and is responsible for completing

information required by EPA land disposal restrictions on the hazardous waste profile sheet. The Environmental

Manager is also responsible for reviewing the hazardous waste profile sheet for accuracy based on the best available

information. Only when the waste has been properly characterized on the hazardous waste profile sheet should the

DTID be certified by the Environmental Manager. The Environmental Manager must maintain a copy of each

hazardous waste profile sheet in the hazardous waste file for the installation for at least five years from the final date

of disposal of the waste stream.

• Base Bioenvironmental Engineering Services (BES) will advise on completion of the health and hazardous waste

identification portions of the hazardous waste profile sheet in Part II, Sections 1-4 and the special handling

information in Section 5. Bioenvironmental Engineering Services also reviews the hazardous waste profile sheet for

technical accuracy when requested by the Environmental Manager. Bioenvironmental Engineering Services should

also maintain a copy of each hazardous waste profile sheet in the generating activities’ shop folder for five years.

• The Base Transportation Officer will advise on completion of the proper shipping information, containers, and

transportation requirements of Part II, Section 5 of the hazardous waste profile sheet.

• The generating activity will submit an updated hazardous waste profile sheet to the disposal agent by 1 December of

each year or whenever the waste stream changes regardless of whether the waste stream was analyzed during the past

year.
AFPAM 32-7043 Attachment 2 1 November 1995 127

4.10. Waste Analysis Plan Revision.

4.10.1. The AAFB waste analysis plan will be evaluated and reviewed annually by BES to ensure that the most up-to-date

procedures are conducted. The plan will also be reviewed and revised whenever:

• sample frequencies change due to annual volume of installation’s hazardous waste streams,

• analytical parameters change due to changes in the processes generating hazardous waste,

• EPA hazardous waste numbers and/or UN/NA identification numbers change due to regulatory revisions, and

• disposal methods change due to revisions to land disposal restrictions or changes in disposal contracts.
128 AFPAM 32-7043 Attachment 2 1 November 1995

Figure 4.1. Hazardous Waste Profile Sheet for AAFB Waste Stream AB-001 (Front).

HAZARDOUS WASTE PROFILE SHEET

PART I

A. GENERAL INFORMATION

WASTE PROFILE NO. 

1. GENERATOR NAME

Andrews Air Force Base

2. FACILITY ADDRESS

Protective Coating Shop

207 Knox Street

3. GENERATOR USEPA ID

MD9854761032

Andrews AFB, MD 5. ZIP CODE

20331-5000

4. GENERATOR STATE ID

34097

6. TECHNICAL CONTACT

Lt Col Mike Newberry

7. TITLE

 Env Manager

PHONE

 (301) 981-2348

B. 1 NAME OF WASTE __Waste Abrasive Blasting Media with Paint Chips_________________________________ _____

2 USEPA or STATE WASTE CODE(S) __D007, D008_________________________________________________________

3 PROCESS GENERATING WASTE __Paint Stripping, AB-001__________________________

4 PROJECTED ANNUAL VOLUME/UNITS 20,000 lbs / year 5 MODE OF COLLECTION Drum

6 IS THIS WASTE IS A DIOXIN LISTED WASTE AS DEFINED IN 40 CFR 261.31 (e.g., F020, F021, F023, F026, F027, OR F028)? YES NO

7 IS THIS WASTE RESTRICTED FROM LAND DISPOSAL (40 CFR 268)? YES NO

 HAS AN EXEMPTION BEEN GRANTED? YES NO

 DOES THE WASTE MEET APPLICABLE TREATMENT STANDARDS? YES NO REFERENCE STANDARDS _40 CFR 268.41__

PART II

1. MATERIAL CHARACTERIZATION

 (OPTIONAL-NOT REQUIRED DATA)

4. MATERIAL COMPOSITION

COLOR __Brown___________________________________ COMPONENT CONCENTRATION RANGE

DENSITY _______________ BTU/LB ___________________ Chromium 125 mg/l 0.0125 %

TOTAL SOLIDS ___________ ASH CONTENT ______________ Lead 360 mg/l 0.036 %

LAYERING: MULTILAYERED BILAYERED SINGLE PHASE Non-hazardous 99.95%

2. RCRA CHARACTERISTICS blasting beads -- --

PHYSICAL STATE: SOLID LIQUID SEMI-SOLID

 GAS OTHER

TREATMENT GROUP: WASTEWATER NON-WASTEWATER TOTAL _____________________ 100%

 IGNITABLE (D001) REACTIVE (D003)

FLASH POINT (F) ________ WATER REACTIVE 5. SHIPPING INFORMATION

 HIGH TOC (> 10%)

 LOW TOC (< 10%)

 CYANIDE REACTIVE

 SULFIDE REACTIVE DOT HAZARDOUS MATERIAL? YES NO

 CORROSIVE (D002) TOXICITY CHARACTERISTIC PROPER SHILLING NAME _Hazardous Waste, Solid, 9,

pH _________________ (SEE REVERSE FOR LISTING)

 CORRODES STEEL

NA 3077, PG III, (chromium, lead), RQ

3. CHEMICAL COMPOSITION (ppm or mg/L) HAZARD CLASS 9 U.N. or NA 3077

N.A. NO.

COPPER _ ____________ PHENOLICS _________ ___ ADDITIONAL DESCRIPTION _ __________________________

NICKEL __ ____________ TOTAL HALOGENS ___ ____ METHOD OF SHIPMENT BULK DRUM OTHER: ______

ZINC ______ __________ VOLATILE ORGANICS _______ CERCLA REPORTABLE QUANTITY 1 lb

CHROMIUM-HEX ___________ PCBs _____ __________ EMERGENCY RESPONSE GUIDE PAGE 

(OTHER) _________________________________________ DOT PUBLICATION 5800.4 PAGE NO. 31 EDITION (YR) 93

NOTE: EXPLOSIVES, SHOCK SENSITIVE, PYROPHORICS, RADIOACTIVE,

AND ETIOLOGICAL WASTE NORMALLY ARE NOT ACCEPTED BY DRMO

SPECIAL HANDLING INFORMATION ______________________

6. GENERATOR CERTIFICATION

BASIS FOR INFORMATION

 CHEMICAL ANALYSIS (ATTACH TEST RESULTS)

 USER KNOWLEDGE (ATTACH SUPPORTING DOCUMENTS - Explain how and why these documents comply with RCRA requirements)

_______________________________________________________________________________________________

I, Lt Col Mike Newberry , HEREBY CERTIFY THAT ALL INFORMATION SUBMITTED IN THIS AND ALL ATTACHED DOCUMENTS IS TO THE

BEST OF MY KNOWLEDGE AN ACCURATE REPRESENTATION OF THE WASTES TURNED IN TO THE DRMO. ALL KNOWN OR SUSPECTED

HAZARDS HAVE BEEN DISCLOSED.

SIGNATURE OF GENERATOR’S REPRESENTATIVE DATE

10 March 1994

 DRMS Form 1930

 Oct 90
AFPAM 32-7043 Attachment 2 1 November 1995 129

Figure 4.1. Hazardous Waste Profile Sheet for AAFB Waste Stream AB-001 (Back ).

TOXICITY CHARACTERISTIC LIST

EFFECTIVE: 28 SEP 90 - LARGE QUANTITY GENERATORS

 29 MAR 91 - SMALL QUANTITY GENERATORS

CONTAMINANT EPA

HW No.

(mg/L) CONTAMINANT EPA

HW No.

(mg/L)

 ARSENIC D004 __________________ HEXACHLORO-1,3,- D033 __________________

 BARIUM D005 __________________ BUTADIENE

 BENZENE D018 __________________ HEXACHLOROETHANE D034 __________________

 CADMIUM D006 __________________ LEAD D008 _________360______

 CARBON TETRACHLORIDE D019 __________________ LINDANE D013 __________________

 CHLORDANE D020 __________________ MERCURY D009 __________________

 CHLOROBENZENE D021 __________________ METHOXYCHLOR D014 __________________

 CHLOROFORM D022 __________________ METHYL ETHYL KETONE D035 __________________

 CHROMIUM D007 ______125_________ NITROBENZENE D036 __________________

 O-CREOSOL D023 __________________ PENTACHLOROPHENOL D037 __________________

 M-CREOSOL D024 __________________ PYRIDINE D038 __________________

 P-CREOSOL D025 __________________ SELENIUM D010 __________________

 CRESOL D026 __________________ SILVER D011 __________________

 2,4-D D016 __________________ TETRACHLOROETHYLENE D039 __________________

 1,4-DICHLOROBENZENE D027 __________________ TOXOPHENE D015 __________________

 1,2-DICHLOROETHANE D028 __________________ TRICHOROETHYLENE D040 __________________

 1.1-DICHLOROETHYLENE D029 __________________ 2,4,5-TRICHLOROPHENOL D041 __________________

 2,4-DINITROTOLUENE D030 __________________ 2,4,6-TRICHLOROPHENOL D042 __________________

 ENDRIN D012 __________________ 2,4,5-TP (SILVEX) D017 __________________

 HEPTACHLOR (AND ITS

HYDROXIDE)

D031 __________________ VINYL CHLORIDE D043 __________________

 HEXACHLOROBENZENE D032 __________________

PART III

FOR DRMO USE ONLY

DRMO VERIFICATION

1. DATE VERIFIED ________________________________

2. RESULTS ATTACHED

pH ___________ FLASH POINT _________ SPECIFIC GRAVITY _________ HALIDES (TOX) __________

REACTIVITY: WATER REACTIVITY __________ CYANIDES __________ SULFIDES ___________

TCLP _________________________________________________________________________________________

 _________________________________________________________________________________________

 _________________________________________________________________________________________

 _________________________________________________________________________________________
130 AFPAM 32-7043 Attachment 2 1 November 1995

Chapter 5

ANDREWS AIR FORCE BASE HAZARDOUS WASTE MANAGEMENT PROCEDURES

5.1. Specific Waste Management Procedures. Hazardous waste is temporarily stored at AAFB at facilities within the

following three classifications: initial accumulation points, accumulation sites, and at the permitted storage building.

Hazardous waste may only be accumulated and temporarily stored at the pre-designated areas shown in Figure 3.1 or at

initial accumulation points located in the same area where the wastes are first accumulated. Each type of accumulation area

must comply with the associated requirements outlined below.

5.2. Permitted Storage Facility. DRMO operates a hazardous waste storage facility on AAFB in Building 198. This

facility is permitted to store hazardous waste in accordance with permit STD123456789. The permit application should be

referenced for specific operating procedures and restrictions.

5.3. Accumulation Site Management.

5.3.1. Each accumulation site must comply with the requirements for siting, physical construction, operations, marking,

labeling, inspections, and maintaining a container log.

5.3.1.1. The area used for the accumulation of hazardous waste should be one of the areas specified in Table 3.2. If an

additional accumulation site is required, a location shall be selected in coordination with the Base Environmental Manager

which minimizes the threat of the waste to human health or the environment in the event of a release of the hazardous

waste.

5.3.1.2. AAFB will comply with the following physical requirements for accumulation sites.

5.3.1.2.1. EPA requirements for the location and design of accumulation sites will be met.

5.3.1.2.2. State requirements for the location and design of accumulation sites will be met.

5.3.1.2.3. Accumulation site managers must obtain pre-approval by the Fire Protection Flight, Ground Safety,

Bioenvironmental Engineering Services and the Environmental Manager for the location of new accumulation sites.

Approval must take into consideration potential environmental consequences if hazardous waste is released from the

accumulation site during a spill, release, fire or explosion.

5.3.1.2.4. Containers holding ignitable or reactive wastes must be located at least 15 meters (50 feet) inside the AAFB

property boundary.

5.3.1.2.5. The construction of each accumulation site must include an impermeable base or containment system which is

capable of preventing environmental contamination due to container overfilling or leaks. Concrete containments shall be

treated with a sealant to prevent spills from absorbing into or passing through the concrete. Containers shall not be placed

on dirt, sand, gravel, or grass surfaces.

5.3.1.2.6. Containers shall not be located near any floor drains that lead to sanitary or storm water sewers.

5.3.1.2.7. The base of the containment system shall be sloped to a sump so liquids resulting from leaks, spills, or

precipitation are drained and removed.

5.3.1.2.8. Different types of hazardous waste must be accumulated in separate containers. Non-hazardous waste must not

be mixed with hazardous waste. For example, waste oil, waste paints, and waste abrasive blasting media, etc. should each

be accumulated in separate containers.

5.3.1.2.9. For incompatible wastes, segregated containment must be provided by using either separate containment areas or

by means of separately diked areas, or sloped containment to separate sumps. Hazardous chemical reactions which cause

heat, fire, explosion, pressure, or the evolution of toxic or flammable decomposition products due to incompatible chemical

reactions must be prevented. If unsure whether a waste to be disposed of or placed in a container is compatible with the

waste in the container itself, contact the Environmental Manager or Bioenvironmental Engineering Services before placing

waste in the container. Incompatible wastes, or incompatible wastes and materials must not be placed in the same

container. In addition, hazardous waste must not be placed in an unwashed container that previously held an incompatible

waste or material.

5.3.1.2.10. Hazardous wastes must not be located near anything with which they are incompatible. For example, lead-acid

batteries should not be located near any aluminum structures or surfaces because contact between acid and aluminum may

produce flammable hydrogen gas and could lead to a fire or explosion. Containers holding hazardous waste which is

incompatible with any other wastes or materials present should be physically separated from the other materials by means of

a dike, berm, or wall.

5.3.1.2.11. Containment systems should be designed and operated to prevent run-on into the container area or with enough

excess capacity (beyond that needed for the waste) so any run-on will be contained. Spilled or leaked waste and

accumulated precipitation must be removed from the system as soon as it is identified to prevent container corrosion or
AFPAM 32-7043 Attachment 2 1 November 1995 131

mixing with wastes. Accumulated precipitation must be checked prior to discharge to ensure that it does not contain

hazardous waste or hazardous waste constituents.

5.3.1.2.12. In areas where unauthorized access to the accumulation site by persons not authorized to accumulate waste in

the containers is possible, security must be provided by a fence or similar access control device. Post signs that read

"Danger - Unauthorized Personnel Keep Out" in English and any other language predominant in the area that can be seen

from any access and large enough to be read at 25 feet.

5.3.1.2.13. “No Smoking” signs must be placed conspicuously wherever there is a hazard from ignitable or reactive waste.

5.3.1.2.14. At outdoor accumulation sites, containers shall be protected from direct sunlight and precipitation by means of a

roof, tarpaulin, or similar device.

5.3.1.2.15. Indoor accumulation sites shall be well ventilated. Highly volatile organics in particular can present a serious

health hazard when in storage. Also, in the event of a spill or leak, effective ventilation should be installed to safely direct

toxic or flammable vapors and fumes out of the work area. Care must be taken to prevent exhausted air from reentering

work areas through doors, windows, and air intakes on buildings.

5.3.1.2.16. Drums must be placed on pallets to allow for ease of removal when full and to keep them away from

accumulated precipitation or spills.

5.3.1.3. Operating Requirements for Accumulation Sites.

5.3.1.3.1. Containers used to store hazardous waste must be kept closed at all times, except for when waste is actually being

added to or removed from the container. In general, a container is closed if its original closures, such as bung caps or drum

heads, are secured to the container. Therefore, a closed-head 55-gallon drum should have its original (or equivalent

replacement) bung caps screwed tightly into the bung openings. During storage, an open-head 55-gallon drum should have

its drum head in place with the retaining ring properly secured with the appropriate nut and bolt. Any other types of

containers used to store hazardous waste should be kept closed in a similar manner.

5.3.1.3.2. Containers must not be stored or handled in a manner which may cause them to rupture or leak. The following

precautions should be taken at both accumulation sites and initial accumulation points to prevent container ruptures and

leaks:

• Containers must not be overfilled; fill to 90% of capacity. For example, only fill a 55-gallon drum to 50 gallons.

Liquids expand in containers as the temperature increases. A steel drum painted a dark color can easily rise to

temperatures above 100 °F and the pressure created by the expansion of the liquid causes bulging heads and damages

the integrity of the container. Bulging containers also create a safety hazard for personnel expected to add waste to

or handle the containers.

• Containers must be protected from freezing during cold weather. Many materials go through a freeze/thaw cycle

during changing weather conditions. This freeze/thaw cycle causes metal stress and can result in leaking containers.

• Containers of ignitable hazardous waste must be grounded. Grounding will prevent build-up of static electricity

which may create a spark capable of igniting flammable vapors. When transferring flammable liquids into

containers, use a bonding wire to connect the container you are pouring from to the container you are pouring into to

prevent sparks caused by the build-up of static electricity during pouring operations. Contact the installation fire

department for grounding and bonding instructions.

• Drums and other containers must be handled and transported with equipment designed for the task. Drum grappler

attachments may be purchased for tow motors to securely grab and move containers. Secure containers to pallets

before moving pallets. Use drum carts designed for the types of containers used by your organization to reduce the

likelihood of dropping a container during handling. Never balance drums on the forks of a forklift or tow motor.

• Use a funnel to fill closed head containers. This will ensure that all waste is poured into the container and does not

spill on the top of the container. If using a funnel without a locking top, the funnel should be removed and the

container closed after filling. If the funnel has any hazardous waste residues remaining, the residues should be

rinsed into the container or the funnel placed in a suitable closed hazardous waste accumulation container.

• Drums must not be stacked more than two high. Drums containing flammable liquids should not be stacked.

• Containers should be stored in an area which is well away from or protected from damage due to the movement of

vehicles such as trucks, fork lifts, POVs etc.

5.3.1.4. Container marking during waste accumulation, shall consist of the following information:

• The words “HAZARDOUS WASTE”;

• Waste description and principal contaminants;

• National Stock Number (if applicable) of predominant waste(s) in the container;

• Organization name, shop code, name of accumulation site manager;

• Accumulation start date; and

• The AAFB-assigned container number.
132 AFPAM 32-7043 Attachment 2 1 November 1995

5.3.1.5. Additional container marking prior to transferring the waste to DRMO or prior to shipping off-base shall consist of

the following information required by EPA and DoT. All marks must be durable, in English, and printed on or affixed to

the surface of a package or on a label, tag or sign, displayed on a background of sharply contrasting color, unobscured by

labels or other attachments and located away from any other marking, such as advertising, that might substantially reduce

its visibility or effectiveness. Each container (also referred to as package) shall be marked with the following information.

5.3.1.5.1. Items in paragraph 5.3.1.4 above shall remain on the container.

5.3.1.5.2. The proper shipping name and the corresponding UN or NA identification number must be marked on each

package of hazardous waste. The proper shipping name is on the hazardous waste profile sheets. Chapter 3 of the Air

Force Hazardous Waste Management Guide, AFPAM 32-7043 provides a method for determining the proper shipping

name and UN or NA identification number for new hazardous wastes.

5.3.1.5.3. Packages containing hazardous substances (see Chapter 3 of the Air Force Hazardous Waste Management Guide

for definition) must be marked with the package with the letters "RQ" in association with the proper shipping name. If the

proper shipping name does not identify the hazardous substance by name, also mark the package with one of the following:

• The name of the hazardous substance as shown in the Appendix to the Hazardous Materials Table;

• The EPA hazardous waste number; or

• For characteristic hazardous wastes, the word "ignitability," "corrosivity," "reactivity," "toxicity," or the

corresponding "D" hazardous waste number.

5.3.1.5.4. When shipping overpacks or other packages with inside packaging containing liquid hazardous wastes, mark the

outside package with an arrow symbol indicating "This Way Up."

5.3.1.5.5. Wastes and materials which are a poison inhalation hazard (special provision codes in column 7 of the

Hazardous Materials Table of 1 - 6 and 18) must be marked "Poison - Inhalation Hazard".

5.3.1.5.6. The EPA hazard warning must be marked on each container of 110 gallons or less. The EPA hazard warning

(preprinted labels can be purchased commercially) contains the wording shown in figure 5.1.

Figure 5.1. EPA Hazardous Waste Mark.

HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal.

If found, contact the nearest police or public safety authority or

the U.S. Environmental Protection Agency.

Generator's Name and Address: ____________________________________

Manifest Document Number: ______________________________________

5.3.1.6. Containers shall be labeled in accordance with the following requirements prior to transfer to DRMO or prior to

shipment off-site.

5.3.1.6.1. DoT hazardous materials warning labels which represent the hazard of the material being shipped must be

affixed to containers before being offered for transportation. It is the responsibility of the generating activity to determine

whether or not labels are required, any multiple labeling requirements, and the proper location of the labels on the package.

5.3.1.6.2. The following steps should be followed to determine and affix the proper DoT label for hazardous waste

shipments in containers, packages, overpacks, or freight containers.

• Locate the hazardous material description as listed in column 2 of the Hazardous Materials Table at 49 CFR 172.101.

• Locate the hazard class (or classes) for the material corresponding to the hazardous materials description in column 3

of the table. Definitions of DoT hazard classes are included in 49 CFR Parts 171-173.

• Locate the hazard label required for each package, as listed in column 6 of the Hazardous Materials Table.

• Place hazard labels on each container next to the proper shipping name marked.

5.3.1.6.3. Some hazardous material descriptions have more than one hazard class listed in the Hazardous Materials Table.

A waste may exhibit one or more of these hazard classes. If the container being shipped contains waste exhibiting only one

of the hazard classes listed in the table, the appropriate label should be affixed to the container. If the container contains

waste meeting the definition of more than one hazard class, multiple labels are required. Multiple labels must be located

next to one another

5.3.1.6.4. Combustible liquids in packages do not require labels.

5.3.1.7. All hazardous waste accumulation sites must be inspected at least weekly (AAFB does not routinely accumulate or

store hazardous waste in tanks; if tanks are ever used for this purpose, the tanks will be inspected daily). During the

inspection, areas where containers are stored must be examined to look for leaking containers and deterioration of

containers and deterioration of the area in which the containers are placed. Each inspection must be documented and will
AFPAM 32-7043 Attachment 2 1 November 1995 133

include the name of the inspector, the location of the accumulation site, date, time of the inspection, problems that the

inspector should be looking for, and a description of actions taken to correct problems when they are detected. The

Environmental Manager will identify the required accumulation site inspection records to be used at AAFB. Inspection

records must be maintained by each accumulation site manager for at least three years from the date of each inspection.

5.3.1.7.1. Inspections of hazardous waste accumulation sites are the responsibility of the accumulation site manager;

however, the Environmental Manager will periodically verify that inspections are being conducted by auditing the

inspection file of each accumulation site manager.

5.3.1.7.2. The Environmental Manager shall also visit each accumulation site at least quarterly to ensure that the

containers and the accumulation area are in good condition and are in compliance with all applicable regulatory

requirements, which include the following:

• The preparedness and prevention requirements of 40 CFR 265, Subpart C;

• The container requirements of 40 CFR 265, Subpart I;

• The tank systems requirements of 40 CFR 265, Subpart J; and

• The generator pretransportation requirements of 40 CFR 262, Subpart C.

5.3.1.8. Accumulation Site Container Log. To account for all drums at an accumulation site, AAFB accumulation site

managers will maintain an accumulation site container log. The accumulation site container log shown in figure 5.2 is used

to record a container identification number assigned to the container by the accumulation site manager and the waste stream

number of the waste in each container. The following data should be recorded on the log.

5.3.1.8.1. The column "Container Number" represents a unique number assigned to each container. The numbering system

should identify the waste stream as well as the individual identity of each container generated by the waste generating

activity. For example, code "AB-001-037" references the 37th drum of paint chips generated by the abrasive blasting

process.

5.3.1.8.2. The column "Waste Steam" is used to enter a brief description of the hazardous waste in each container.

5.3.1.8.3. The column "Start Date" represents one of the following dates. If waste is being added to a container at an

accumulation site, enter the date the first volume of waste was added to the container. If a 55-gallon container is filled at a

initial accumulation point and subsequently moved to the accumulation site, enter the date the container was filled to

capacity.

5.3.1.8.4. "Date Full" is the date the container was filled to capacity.

5.3.1.8.5. "Date Transferred" is a record of the date the container was transferred to DRMO or was shipped from the

accumulation site for treatment, storage or disposal.

5.3.1.8.6. “Shipped To” is a log of the location to which the container was shipped.

5.4. Initial Accumulation Points. An initial accumulation point is an area at or near the point of hazardous waste

generation which has fewer requirements than those provided for accumulation sites, provided the following restrictions are

met.

5.4.1. Hazardous waste accumulation is under the control of the operator of the process generating the waste.

5.4.2. Not more than 55 gallons of hazardous waste or 1 quart of acute hazardous waste may be accumulated. The 55-

gallon limit applies to the total of all the non-acutely hazardous waste accumulated (includes all waste streams combined) at

the initial accumulation point.

Figure 5.2. Accumulation Site Container Log.

Accumulation Site Container Log

Container # Waste Stream Start Date Date Full Date Transferred Shipped To

AB-001-037 Sand blasting waste 5 Jul 94 5 Jul 94 1 Oct 94 DRMO

AB-001-038 Sand blasting waste 6 Jul 94 6 Jul 94 1 Oct 94 DRMO

AB-001-039 Sand blasting waste 10 Jul 94 10 Jul 94 1 Oct 94 DRMO

FC-001-143 Contaminated JP-4 8 Aug 94 30 Aug 94 1 Oct 94 Ajax Recycling

PO-002-057 Spent PD 680 9 Aug 94 15 Sep 94 5 Nov 94 DRMO

AC-004-10 Solvent

contaminated rags

3 Sep 94 15 Oct 94 5 Nov 94 DRMO

5.4.3. Hazardous waste may be accumulated indefinitely until either of the restrictions in items a or b are exceeded.

5.4.4. Initial accumulation points must comply with the following requirements.
134 AFPAM 32-7043 Attachment 2 1 November 1995

5.4.4.1. Hazardous waste at initial accumulation points must be collected in containers, not tanks.

5.4.4.2. If the 55-gallon limit is exceeded at a initial accumulation point, the container holding the waste must be marked

with the date the excess began accumulating. Within three days the waste must be transferred to either an accumulation site

or to the permitted hazardous waste storage facility (Building 198). If over 55 gallons of hazardous waste remains at a

initial accumulation point beyond this time limit, the initial accumulation point is regulated under the more stringent

requirements for accumulation sites.

5.4.4.3. Each initial accumulation point must also comply with the requirements for accumulation sites in paragraph 5.3.1.

above.

• Paragraphs 5.3.1.2.4, 5.3.1.2.6, 5.3.1.2.8 through 5.3.1.2.10, and 5.3.1.2.13 through 5.3.1.2.16 regarding the

physical requirements for accumulation sites.

• Paragraphs 5.3.1.3.1 through 5.3.1.3.3 regarding operating requirements for accumulation sites.

• Paragraph 5.3.1.4 regarding container marking during accumulation.

• Paragraph 5.3.1.5 regarding container marking prior to turn-in.

• Paragraph 5.3.1.6 regarding container labeling prior to turn-in.

5.5. Hazardous Waste Turn-in to DRMO. After temporary accumulation at the point of generation, most hazardous

waste generated at AAFB is transferred to DRMO which operates a permitted storage facility in Building 198. Turn-in of

hazardous waste requires three documents; an up-to-date hazardous waste profile sheet, AF Form 2005, and DD Form

1348-1.

5.5.1. All transfers of hazardous waste to the DRMO storage facility must be conducted under the direction of and

processed through the Environmental Manager. This procedure will prevent unnecessary waste analyses and handling of

the waste. It also provides for an accurate accounting of fund expenditures.

5.5.2. Before turning in hazardous waste, the waste generator should complete an AF Form 2005 (figure 5.3) in

cooperation with the Environmental Manager and Base Supply. The Environmental Manager will provide oversight and

assistance in completion of the AF Form 2005 and waste turn-in, as follows.

• Assist in determining the EPA hazardous waste number. Bioenvironmental Engineering Services may be consulted

for assistance in this determination.

• Identify the cost of disposal and unit of issue (which are used to establish the hazardous waste item record in supply).

The disposal price and unit of issue are obtained from the applicable DRMO disposal contract. The unit price

represents the cost, per unit of issue, to dispose of the specific waste.

• Inspect the waste and certify that the waste is identified, packed, marked and labeled in accordance with federal and

state hazardous waste management or toxic substance control regulations. This certification must be on or

accompany the turn-in document (DD Form 1348-1) before it is received by DRMO. If the waste is not properly

identified, packed, marked or labeled, it is the responsibility of the generating activity to make appropriate

corrections or repackaging, as identified by the environmental function.

Table 5.1. Common Federal Stock Classes.

9150 Petroleum, oils, lubricants 8010 Paints, waste paint related material

6350 Antifreeze, windshield washer fluid 6850 Solvents

5950 Transformers 9999 Spill residue

5.5.3. The specific entries to be completed by the generator on the AF Form 2005 include the following.

• Enter “TIN” in blocks 1-3 to designate a turn-in action.

• Enter the Stock Number in positions 8-22. The Stock Number contains the Federal Stock Class in positions 8-

11, the constant "PHW" in positions 12-14, the EPA hazardous waste number in positions 15-18, and the

contract line item number (CLIN) in positions 19-22. See Table 5.1 for sample Federal Stock Class

designations. Contact Base Supply for other Federal Stock Classes and the appropriate CLIN for each waste

generated.

• In blocks 23 and 24, enter the unit of issue of the waste’s CLIN.

• In blocks 25-29, enter the quantity of the waste being turned in. This will be the total quantity of the waste

being turned in. One drum of the waste would be 00050, if two drums were turned in the quantity would be

00100.

• Enter the Document Number in positions 30-43; it will contain activity code "R," the organization, and shop

code of the generating activity, the current Julian date, and the next available serial number taken from a

locally devised off-line control register.
AFPAM 32-7043 Attachment 2 1 November 1995 135

• For hazardous waste, enter "H" for the Material Condition Code in position 44.

• Enter the number "9" for the Action Taken Code in position 62.

• The words "Hazardous Waste" should be entered in Block D to readily identify the type of documentation to

Base Supply.

5.5.4. The accumulation site manager or designee is required to take the completed AF Form 2005 to Base Supply, who

will input the data from the form into the Base Supply computer system and generate a DD Form 1348-1 disposal document

(figure 5.4). Copy 1 of AF Form 2005 will be filed in document control after processing and copy 2 will be returned to the

generating activity. The DD Form 1348-1 is the document that should accompany the waste for turn-in to the installation

hazardous waste storage facility.

5.5.5. The Base Supply representative will sign both copies (original and duplicate) of the DD Form 1348-1 in block W.

The words "Hazardous Waste" should be entered on the face of the disposal document by either the Base Supply

representative or the hazardous waste generator. The person from the generating activity should then enter the date and

time in block 13 and print and sign his or her name in blocks 14 or 15 on both books (original and duplicate) of the disposal

document.

5.5.6. Copy 1 and copy 5 of the DD Form 1348-1 disposal document will be retained by Base Supply, who will eventually

forward them to Document Control. The remaining copies will be given to the person from the generating activity, who

must hand carry the document to the Environmental Manager. The Environmental Manager will record the disposal

document number and the cost of disposal on the reverse side of an AF Form 616, Fund Cite Authorization, and attach a

copy of the DD Form 1348-1 to the AF Form 616. The Environmental Manager will also ensure that the hazardous waste

turned in to DRMO for disposal is weighed in the presence of an authorized DoD representative.

5.5.7. The generator should then take the remaining copies of the DD Form 1348-1 to the storage facility (with the

hazardous waste). The generator must also ensure that an up-to-date hazardous waste profile sheet is turned in with the

waste. The generator retains two copies for base records after acceptance of the waste by the operator of the storage facility.

The generator must then return one copy of the disposal document signed by the storage facility operator to the

Environmental Manager.

5.5.8. DRMO may require the generator to retain custody of the waste while DRMO administratively manages the off-site

disposal or reclamation of the waste. There may be some wastes which may not be accepted by the local DRMO. If DRMO

refuses to accept the transfer of accountability of a hazardous waste, the Environmental Manager should be immediately

notified to resolve the conflict.

5.6. On-Installation Transportation.

5.6.1. It is important to ensure that any waste transported on-installation is transported in a manner that will not endanger

the health of installation personnel or the environment. The activity that generates hazardous waste must ensure that

hazardous waste is accumulated and subsequently transported in the proper DoT-specification containers. To determine the

proper container to use, refer to the Hazardous Materials Table at 49 CFR 172.101.

Figure 5.3. Sample AF Form 2005, Issue/Turn-In Request.
136 AFPAM 32-7043 Attachment 2 1 November 1995

Figure 5.4. DD Form 1348-1 , DoD Single Line Item Release/Receipt Document (Used as Disposal Turn-in

Document)

5.6.2. The accumulation site manager should also ensure that containers are in good condition. Prior to turning in

hazardous waste, each container should be inspected by the accumulation site manager and the Environmental Manager to

ensure that it is in good condition and suitable for transportation. The container should have no leaks and no accumulation

of liquid on the top head. Also, there should be no serious corrosion, dents, sharp creases, or bulging heads. If the

container has a leak or if it is not in good condition, the waste in the drum must be transferred to a container in good

condition or the container must be overpacked in a salvage drum.

5.6.3. If the accumulation site manager or waste generator does not belong to an organization that has the authorization to

transport hazardous waste on-installation, the Transportation Squadron (5234) should be contacted to arrange for waste

pick-up and transportation. Before the vehicle leaves with the waste it should be closely inspected. If the vehicle is

carrying containers, the vehicle should be inspected to ensure that containers are securely loaded and that incompatible

wastes are not loaded next to each other. Vehicles transporting bulk wastes should be examined to ensure that all pumps,

valves, and fittings are closed tight and secured.

5.7. Record Keeping.

5.7.1. RCRA requires the maintenance of certain records on-base. The type of records, along with the retention time and a

reference to a description of each record, is presented in Table 5.2. The Environmental Manager shall maintain or know

the whereabouts of the files identified in the table and shall make them available to appropriate state and Federal inspectors

upon request.

5.7.2. The Environmental Manager will also maintain copies of hazardous waste profile sheets, DD Form 1348-1, and the

monthly M-15 reports, which are received from Base Supply and list all hazardous waste transfers to the DRMO for at least

five years after disposing of the waste streams covered by the reports. The Environmental Manager will also maintain an

updated copy of this Hazardous Waste Management Plan and accompanying hazardous waste stream inventory and waste

analysis plan.

5.8. Reporting.
AFPAM 32-7043 Attachment 2 1 November 1995 137

5.8.1. Annual Report. The State requires annual reports from hazardous waste generators and treatment, storage, and

disposal facilities by March 1 of each year covering hazardous waste activity over the previous calendar year. Each annual

report should shall include the following information:

• Installation EPA identification number, name, and address;

• The calendar year covered by the report;

• The EPA identification number, name, and address of each off-site treatment, storage, and disposal company in the

United States to which hazardous waste was shipped during the reporting year;

• The name and EPA identification number of each transporter used during the reporting year;

• A description, EPA hazardous waste number, DoT hazard class, and quantity of each hazardous waste shipped

off-site to a TSDF (listed by TSDF EPA identification number);

• A description of the efforts undertaken during the reporting year to reduce the volume and toxicity of waste

generated;

• A description of the changes in volume and toxicity of waste actually achieved during the reporting in comparison to

previous years; and

• A certification signed by the Base Commander or authorized representative.

5.8.2. Emergency Reports. Releases of hazardous waste, hazardous substances, and hazardous materials onto the land or

into the waters of the state must be immediately reported to the State Division of Environmental Management at (555)

555-5291 during business hours or via the State Highway Patrol 24-hour number (800) 555-7935 (in state) after business

hours. See the Andrews Air Force Base HAZMAT Plan for additional requirements regarding the reporting of hazardous

waste spills, releases, fires, or explosions.

5.8.3. Incident Report. In the event that the contingency portion of the HAZMAT Plan is implemented, an incident report

must be submitted within 15 days after the incident to the Department of Human Resources Hazardous Waste Branch, as

described in AAFB's HAZMAT Plan.

5.8.4. Within 60 days of the completion of final closure of the hazardous waste storage facility (Building 198), the base

must submit to the EPA Regional Administrator, by registered mail, a certification that the facility has been closed in

accordance with the specifications of the approved closure plan. The certification must be signed by the facility operator

and an independent registered professional engineer.

5.8.5. If requested by EPA or otherwise required by regulatory requirements, the installation must submit reports pursuant

to 40 CFR 264 (or 265, as appropriate) Subparts F and K through N.
138 AFPAM 32-7043 Attachment 2 1 November 1995

Table 5.2. RCRA Records and Corresponding Minimum Retention Periods.

Record or File Retention Time Citation

Hazardous waste determination

documentation

5 years from the date that the waste was

last sent to a treatment, storage, or

disposal facility†

40 CFR 268.7(a)(7)

Annual report 3 years from the due date of the report† 40 CFR 262.41

Hazardous waste manifest 5 years from the day the waste was

accepted by the initial transporter†

40 CFR 262.20

Accumulation site inspection logs 3 years from the date the inspection was

conducted†

40 CFR 262.34

40 CFR 265.15(d)

40 CFR 265.174

Exception reports 3 years from the due date of the report† 40 CFR 262.42

Land disposal restriction notice &

certification

5 years from the date the waste was last

sent to a TSDF†

40 CFR 268.7

Notification of intent to export waste 3 years from the date the hazardous

waste was accepted by the initial

transporter†

40 CFR 262.53

EPA acknowledgement of consent

(for exports)

3 years from the date the hazardous

waste was accepted by the initial

transporter†

40 CFR 262.51

40 CFR 262.53

Waste export confirmation of delivery 3 years from the date the hazardous

waste was accepted by the initial

transporter†

40 CFR 262.54

Annual report (required of primary

exporters of hazardous waste)

3 years from the date the hazardous

waste was accepted by the initial

transporter†

40 CFR 262.56

Employee training records Current personnel: until closure of

facility; former personnel: 3 years from

date the individual last worked at facility

40 CFR 262.34

40 CFR 265.16

† The periods of retention are extended automatically during the course of any unresolved enforcement

action or as requested by EPA.
AFPAM 32-7043 Attachment 2 1 November 1995 139

Chapter 6

TRAINING

Section A--Hazardous Waste Training Requirements.

6.1. Personnel for Which Training is Mandatory.

6.1.1. Hazardous waste management training is required for personnel who handle hazardous waste at facilities which fit

into any of the following categories:

• permitted hazardous waste storage facility (Building 198);

• hazardous waste accumulation sites; or

• emergency response organizations which may respond to hazardous waste incidents.

6.1.2. In addition to personnel identified in item a above, all AAFB personnel who perform any of the following tasks must

receive hazardous waste training:

• decide which wastes are hazardous waste;

• add hazardous waste into accumulation containers or tanks at accumulation sites;

• remove hazardous waste from accumulation tanks or containers;

• transport hazardous waste to or from accumulation sites;

• transport hazardous waste to or from storage and treatment units;

• respond to spills, fires, or explosions, involving hazardous waste;

• complete hazardous waste manifests, annual reports, or exception reports;

• inspect hazardous waste accumulation sites, storage, treatment, or disposal facilities;

• operate accumulation sites;

• work at permitted or interim status TSDF; or

• conduct any tasks involving occupational exposure to or which require management of hazardous waste.

6.2. Training Frequency. The required training must be successfully completed by all of the personnel described above.

For new personnel, training must be successfully completed prior to their assignment to a positioning involving the

handling or management of hazardous waste. Until that time, untrained personnel must not perform any tasks involving

hazardous waste management unless they are supervised by trained personnel. Facility personnel identified in section 6−1

must take part in an annual review of the training program.

Section B--Training Scope.

6.3. Training Components. There are two general components to the training required by RCRA in 40 CFR 265.16.

Personnel must be trained: 1) how to perform their duties in a way that ensures AAFB compliance with hazardous waste

regulations; 2) hazardous waste management procedures, including contingency plan implementation; and 3) how to

respond to emergencies involving hazardous waste.

6.4. Air Force Hazardous Waste Management Training Program. AAFB uses the Air Force Hazardous Waste Training

Program to train applicable base personnel. The Air Force has developed a slide presentation and a computer-based

training (CBT) program to help meet Federal hazardous waste training requirements. The programs are geared to

flightline, maintenance, and other AF personnel who generate and transport hazardous waste. To fully comply with all

regulations, both programs must be tailored to meet each installation's specific requirements. AAFB's specific procedures

for waste determination, accumulation, transportation, and turn-in, must be incorporated into the training program, along

with the emergency response procedures. All hazardous waste training must include the most current Federal, State, and

local requirements. Each training course offering must be customized to fit the specific hazardous waste management

requirements of the attendees. Arrange training for similar activities at the same time. For example, present one course

offering for installation activities that generate hazardous waste as a result of painting operations (i.e., the CE paint shop,

aircraft painting operations, missile maintenance, etc.), another offering for activities that generate hazardous waste from

cleaning and degreasing operations (i.e., transportation, aircraft maintenance, etc.), and another for operators of the

hazardous waste storage facility.

6.5. Required Records. Training records are required to document that all appropriate personnel have successfully

completed their required training. The following records should be maintained by the Environmental Manager.
140 AFPAM 32-7043 Attachment 2 1 November 1995

• The job title for each position at the installation related to hazardous waste management and the name of the

employee filling each job.

• A written job description for each position related to hazardous waste management. For the purposes of RCRA

training records, the job description need only describe the job as it relates to the management of hazardous waste

and must include the requisite skills, education, or other qualifications, and the duties of facility personnel assigned

to each position.

• A written description of the type and amount of both introductory and continuing training that will be given to each

person filling a position related to management of hazardous waste.

• Records that document that the training or job experience required to meet the training requirements have been

provided to and completed by base personnel. These records must be kept for current employees as long as they work

at the installation, and for an additional three years after the date they leave the base (or stop working at a position

related to hazardous waste management). Training records may accompany personnel transferred to another

installation.
AFPAM 32-7043 Attachment 2 1 November 1995 141

Chapter 7

RESPONSE TO EMERGENCIES

7.1. Emergency Response Procedures and Contingency Plan Requirements. AAFB has written emergency response

procedures for hazardous waste generating activities and for the hazardous waste storage facility. The required emergency

response and contingency plan requirements have been incorporated into the AAFB Hazardous Materials Emergency

Planning and Response Plan, called the HAZMAT Plan. The HAZMAT Plan is distributed to all base activities that

generate hazardous waste. Emergency response activities relating to hazardous waste spills, fires, or explosions involving

hazardous waste shall be in accordance with the HAZMAT Plan.

7.2. Implementation. The AAFB HAZMAT Plan must be implemented whenever there is a spill, fire, explosion or release

of hazardous wastes. All incidents involving hazardous waste or hazardous substance spills or releases must also be

immediately reported to the AAFB Fire Department at 911. All incidents off-base involving hazardous waste generated at

AAFB must be immediately reported to the local emergency reporting number, then reported to the Consolidated Command

Post at (555) 555-3121.
142 AFPAM 32-7043 Attachment 2 1 November 1995

Chapter 8

POLLUTION PREVENTION

8.1. Pollution Prevention Program Plan. Andrews Air Force Base has prepared a Pollution Prevention Program Plan

(P3P) in order to protect and enhance the environment and reduce occupational safety and health risks to AAFB personnel

The P3P is maintained by the Environmental Manager as a stand-alone plan.

8.2. Scope of the P3P.

8.2.1. The P3P supports the concept of reducing AAFB's use of hazardous and toxic substances and the generation of

wastes through source reduction and environmentally sound recycling. According to the P3P, generation of hazardous

substances, pollutants, or contaminants will be reduced or eliminated at the source; pollution that cannot be prevented at the

source will be recycled in an environmentally safe manner; pollution that cannot be recycled will be treated in an

environmentally safe manner; and disposal or other releases to the environment will be employed only as a last resort and

will be conducted in an environmentally safe manner.

8.2.2. The P3P covers not only hazardous waste minimization, but also includes the following topics:

• Industrial maintenance and clean-up operations involving hazardous and other wastes

• Municipal solid waste

• Non-point source pollution

• Material procurement, supply, and distribution

• Education and incentives

• Systems acquisition

• Allied programs associated with pollution prevention including comprehensive planning, energy and transportation

efficiency, and natural resources value.